Ivory Bill

Written evidence submitted by a law firm who wish to remain anonymous (IVB12)

1 Introduction

1.1 [THE LAW FIRM] is an English law firm, based in London, with one of the leading practices in art and cultural heritage law.

1.2 We act for individuals, art businesses, collectors, institutions and academics within the art industry and hereby submit evidence to the Committee in respect of the scope of the proposed exemptions set out in the Ivory Bill. Our clients who will be most affected by the Ivory Bill include ancient art dealers, some of whom have been established for more than a century and each of whom have specialist expertise ranging from Indian, Japanese, Chinese and Tribal art and artefacts, academics and museum curators, all of whom share a common interest: to preserve Cultural Artefacts [1] of cultural, historical and artistic importance. We therefore submit our evidence to protect the interests of our clients and request that the Committee considers an amendment to the Ivory Bill to permit the legal trade of antique ivory valued for its cultural, historical and artistic significance.

1.3 This evidence is submitted in our capacity as legal advisor to numerous art clients who will be adversely affected by the Ivory Bill.

2 Summary

2.1 We fully support the objective of the Ivory Bill and the Government’s determination to regulate the trade in all ivory in order to combat the illegal ivory trade, prohibit the trade in modern day ivory artefacts and to eradicate ivory poaching (the "Objective").

2.2 During the Second Reading of the Ivory Bill (the "Second Reading"), SoS Michael Gove ("SoS") acknowledged that there was worldwide acceptance that there is a need for exemptions to reflect past uses of ivory where it was deployed for artistic or cultural reasons to produce certain specific artefacts at specific times that have a particular value. [2] The SoS noted the acceptance of exemptions for portrait miniatures, which are valuable not because they are painted on ivory but because they are examples of "exquisite artistic endeavour". [3] He also referred to the exemption for items with a de minimis content of ivory, which "no one is buying and selling because of the ivory but of which the ivory is an integral part". [4] As demonstrated in this submission, the same is true for Cultural Artefacts which are traded for their cultural, historical and artistic qualities and not their material value.

2.3 Further, as is apparent from the Response to the Consultation and the Second Reading, the majority of the NGOs and wildlife groups that have campaigned for the Ivory Bill also acknowledge and agree that narrowly defined exemptions do not contribute to poaching of ivory. [5]

2.4 We respectfully submit to the Committee, and demonstrate in the evidence presented herein, that:

(i) absence of an exemption for trade in Cultural Artefacts from the Ivory Bill is an unlawful derogation from EU law;

(ii) there is no evidence to suggest that the trade in Cultural Artefacts of cultural, historical or artistic importance contributes to the continued poaching of ivory;

(iii) Cultural Artefacts are not collected, studied or traded for their ivory content and further, the ivory content in Cultural Artefacts bears no correlation to the value of such artefacts. The value and appeal of Cultural Artefacts is in their cultural, historical and artistic significance;

(iv) the Government has already accepted the need for certain exemptions where it must be established that the object dates from before 1918, 1947 or 1975 so any supposed challenges in dating objects should not be seen as a reason to reject an exemption for Cultural Artefacts pre-dating 1947. It is no more or less difficult to date an artefact to pre-1947 than it is to date an object to pre-1918 or pre-1975 [6] ;

(v) the Government could implement stricter measures to ensure the Ivory Bill is enforced effectively and still meets the Objective but also preserves and protects the continued trade in Cultural Artefacts; and

(vi) the Ivory Bill without the Proposed Exemption is a violation of Article 1 Protocol 1 of the ECHR [7] .

3 Compliance with EU Law

3.1 It is respectfully submitted that the Ivory Bill requires amendment in order to comply with EU law for so long as EU law continues to have effect in the UK, whether under current, transitional or backstop arrangements or otherwise.

3.2 The Convention on International Trade in Endangered Species of Wild Fauna and Flora ("CITES") is implemented within the EU by Council Regulation (EC) No 338/97 (the "Principal EU Regulation"), Commission Regulation (EC) No 865/2006 (the "Subsidiary EU Regulation") and Commission Implementing Regulation (EU) No 792/2012. All of these EU Regulations are directly applicable in the UK.

3.3 Article 8(1) of the Principal EU Regulation prohibits commercial dealings in specimens of listed species including elephants but subject to exemptions listed in Article 8(3). Article 8(3) includes an exemption for "worked specimens that were acquired more than 50 years previously", meaning 50 years before the coming into force of the Principal EU Regulation (i.e. before 1 March 1947). This is commonly referred to as the "antiques exemption" and in this note, such specimens are referred to as Cultural Artefacts. Article 62(3) of the Subsidiary EU Regulation provides that no certificate is required for Cultural Artefacts meeting the "antiques exemption". As such, there can be no question of Member States having a discretion to prohibit commercial dealing in Cultural Artefacts that meet the requirements of the exemption.

3.4 It is a core principle of the EU internal market that once a good has entered lawfully into the EU at any point it can thereafter move freely between Member States, subject only to any rules of EU law or lawful derogations imposed by EU Member States under their domestic law on public policy grounds.

3.5 There is no scope in this case for the UK to abrogate or narrow the "antiques exemption" because EU law only allows a Member State to legislate in an area of shared competence to the extent that the Union has not already exercised its competence (Article 2(2) of the Treaty on the Functioning of the European Union). Further, paragraph (5) of the preamble to the Subsidiary EU Regulation makes it clear that its purpose is to ensure that the derogations from internal trade in Article 8(1) of the Principal EU Regulation are uniformly applied between Member States; i.e. it is explicitly a harmonising measure.

3.6 If, contrary to the above, there is any scope to derogate from the relevant provisions of EU law on public policy grounds it is nevertheless circumscribed by a requirement to comply with the general principles of EU law, including the requirement of proportionality enshrined in Article 6 of the Treaty on European Union. In particular, and at a minimum, the UK would have to show that any permitted object of protection could not be achieved just as effectively by measures which were less restrictive of Union trade.

3.7 We are not aware of any evidence that shows that trade in Cultural Artefacts poses any threat in itself to the continued survival of elephants. To the extent there are legitimate concerns about the existing exemption, it seems to us that these focus on its inappropriate application to post-1947 ivory and difficulty in enforcing the exemption. In other words, the concern is less about the terms of the exemption than about its practical application. Those concerns could be effectively addressed by imposing more rigorous requirements to prove compliance with the exemption. Such measures are set out in this submission at paragraph 6.

3.8 We set out in the Annex to this submission the Proposed Amendment to the Ivory Bill that is intended to preserve the existing "antiques exemption" for Cultural Artefacts but establish a more rigorous process for establishing compliance with the same. We should be grateful if the Committee would give consideration to this alternative to the existing language.

4 Acknowledgement of the Need for Exemptions

4.1 It is clearly acknowledged and agreed by both the Government [8] and interested NGOs that exemptions to the ivory ban , including date - based thresholds, a re necessary to exempt objects valued not for their ivory, but for their cultural and artistic value. Examples of these acknowledgments are numerous in both the Responses to the Consultation and were cite d throughout the Second Reading. For example :

· T he WWF stated that it did not believe that exemptions would have a negative impact on the poaching of elephants or the illegal ivory trade. [9] ;

· The International Fund for Animal Welfare (IFAW) a ccepted the portrait miniatures exemption " on the grounds that they do not fuel the continued poaching of ivory " . [10] ;

· In relation to the proposed Musical Instruments exemption, the Responses to the Consultation states: a combined response of eight conservation NGOs suggested a backstop date of 1975, arguing that the "1980s saw the highest levels of poaching in recent history as elephant populations in Africa were reduced by 50% from c1.2 million to c600,000 in only ten years." 1975 is the date that Asian elephants were first listed on CITES "; [11] whereas 1947 was the date supported by the WWF . [12]

4.2 The reasons advanced in support of an exemption for musical instruments included that (i) the ivory in existing musical instruments is incidental ; (ii) instruments containing ivory were not valued for their ivory content, but for their craftsmanship and musical quality ; and (iii) many musicians use their instruments as an investment for their retirement . [13]

4.3 These submissions are equally true for Cultural Artefacts . There has been no evidence to d emonstrate that the cultural appreciation of musical instruments (which the Government and the NGOs have accepted does not impact the Objective) differs in any way to the appreciation of Cultural Artefacts which are also valued for their cultural significance.

5 Cultural Artefacts are not Collected for their Ivory Content

No-one Collects or Specialises in "Ivory"

5.1 As set out in the preceding paragraphs, the Government and the NGOS acknowledge and agree that portrait miniatures and musical instruments created prior to certain dates should be exempt from the proposed ban as they are not valued for their ivory content, but are significant and important examples of history, cultural and artistic behaviour of the past. The same is true for Cultural Artefacts, which should also be exempt for the same reasons and subject to a date-based threshold.

5.2 It is evident when one considers Cultural Artefacts that these items are not traded for their ivory content.

5.3 Collectors and specialists do not collect, research or specialise in "ivory". Their specialism is in the origin of the item, its history and the technique used to create the artefact. One would not find a collector, scholar, art dealer or museum who had an "ivory collection". The collection would be Japanese Netsuke, or Tribal artefacts (some of which may be ivory, some of which are not), Indian or Islamic idols, or Chinese fans that happen to be made partly from ivory as was the practice of the time. One only needs to look at the vast differences between the collections of two museums, for example the Greenwich Fan Museum [14] against the Islamic and Middle East collection at the Ashmolean Oxford [15] , or compare a tribal mask to a Japanese Netsuke to realise that their cultural significance and financial value does not come from the ivory that happens to have been used in their construction.

5.4 To further illustrate that the ivory in Cultural Artefacts is not the relevant factor, one of our clients explained that they were in fact prohibited by their insurance policy to opine on or value items beyond their specialist expertise, despite the item being an ivory statue of a similar age to many items in its own collection. As the relevant item was not within their very specialist area of expertise, they would not be considered qualified to assess the value and significance of it. If it was in fact true that Cultural Artefacts were only traded and valued for their ivory content, this would qualify any expert with a specialism in some form of ivory to opine on another ivory artefact, be it a Chinese fan, 17th century French bureau or an Islamic carved chest.

Ivory Content has no bearing on the Value

5.5 During the Second Reading it was argued by the SoS that portrait miniatures should also be exempt because they are tiny but hugely significant. [16]

5.6 We respectfully submit that Japanese Netsuke are also "tiny" and hugely significant because they are examples of culture, art and history. Like portrait miniatures, Japanese Netsuke could not be easily re-carved and therefore bear no more risk for being traded for their ivory content than portrait miniatures.

5.7 MP Owen Paterson identified during the Second Reading that the current value of ivory is $700 per kilogram. [17] If ivory was indeed traded and valued for its ivory alone, this would mean Japanese Netsuke items (weighing less than 100 grams) would cost approximately $70 each, whereas in fact those items cost tens of thousands of pounds due to their cultural significance. We also note, in passing, the irony that Japanese Netsuke have a far lower ivory content by weight and volume than many items that will be exempted under the proposed de minimis low ivory content exemption in clause 7 of the Ivory Bill.

5.8 A second example, is in respect of a sale of two items by one of our clients, of 16th century antique artefacts which had identical dating, origin and provenance, having been in the same collection since their discovery 100 year prior. The weight of the two items was similar and both were made wholly of ivory, however, the purchase price for one item was more than 10x the price of the other. The difference in price was solely due to the cultural and historical significance of one of the items and what each depicted. The more expensive item was much rarer than the other and depicted a spiritual icon, whereas the other was used for adornment and did not have a religious or spiritual connection in its country of origin. This example, which is typical of Cultural Artefacts, demonstrates that the material used to make these artefacts bears no correlation to the value or appreciation for such objects, which are valued for cultural and historic significance.

5.9 For the reasons set out in this submission, we respectfully submit that there is no distinction between the reasons portrait miniatures and musical instruments are valued and traded and the reasons Cultural Artefacts are valued and traded.

6 Proposed measures as to how the exemption can be enforced

6.1 SoS expressed concern during the Second Reading that the existing restrictions currently in place did not work. [18] SoS stated that:

The existence of the current legal market allows illegally obtained ivory to pass as legally acceptable ivory or worked ivory for sale. In effect, that means that criminal organisations and those who are driven by the significant profits to be made by selling ivory into markets where there is a demand can use the weakness of the existing provision to pass illegal material off as legal. [19]

6.2 However, there are various measures that could be implemented to ensure compliance with exemptions, some of which have been suggested in the Second Reading and many of which are supported by our clients, and the wider art industry who have expertise in this area. To the extent there have been issues to date it is only because there is no obligation to prove the date of an object before dealing in it. A system of certification and registration prior to dealing, with the onus of proof firmly on the owner, would address the concerns that have arisen to date.

6.3 As already anticipated in the Ivory Bill, one method to ensure Cultural Artefacts are identified as being "antique" (pre-1947) would be the establishment of a panel of experts able to administer certification in a timely and authoritative manner. The art industry is already well used to dating Cultural Artefacts through various techniques, including comparables, connoisseurship and examining documents and provenance. This traditional technique has been used and relied upon for generations, and is used in museums worldwide. As noted elsewhere in this submission, it would be unrealistic to expect to have an expert panel of "ivory experts" as each origin is a different specialism. An expert panel could mirror that of the Arts Council England export licensing committee, where experts in a particular field could be consulted depending on the item in question.

6.4 As the rare items, portrait miniatures, musical instruments and de minimis exemptions are all date based, we infer that the Government has already satisfied itself that dating techniques can be sufficiently reliable. Further, we note that the approach proposed for rare items is to use exactly the sort of panel of experts that we would propose for Cultural Artefacts. We therefore submit that the same technique can be easily applied to Cultural Artefacts on the basis of the 1947 threshold.

6.5 Of course, such reviews would come at a cost, and whilst the cost would have to come from the owner seeking a passport or certificate for the object, this would be a much more proportionate means than an outright ban on Cultural Artefacts. Further, the cost in itself would deter trading in lower value items where it might be arguable that the value lies more in the ivory content than in cultural, historical or artistic elements. Thus, for example, a £500 fee might be seen as reasonable to allow a sale of a Japanese Netsuke worth £10,000 but would obviously not facilitate trade in items of similar size where the value lay only in the ivory content (perhaps $70 worth, as noted above).

6.6 A further measure that could be used would be to prohibit dealing without the involvement of a statutorily licensed dealer where the system for licensing would require a high standard of due diligence and compliance, and where licences could be revoked in the event of non-compliance.

7 Right to Property

7.1 In the Response to the Consultation, the Government accepted that one of the reasons it ought to grant an exemption for musical instruments, was due to many musicians using their instruments as an investment for retirement. [20] The same can be true for specialist art dealers, curators, scholars and collectors who may individually have chosen to acquire or collect artistic or historical items for passion and interest, but in the knowledge that they would be financially valuable in the future. It is also true for individuals and families who may have acquired, collected or inherited Cultural Artefacts containing ivory which as a result of the Ivory Bill, will subsequently be rendered financially worthless.

7.2 It was estimated in 2017 that there could be two million artefacts containing ivory in British homes, whose owners could suffer a financial loss from a total ban. [21] Several of our clients reported to us that they have received numerous emails from members of the public asking for advice as to what they can now do with their family heirlooms. Members of the public, perhaps with only one valuable item they may have inherited or collected may now be faced with the dilemma as to whether to sell their Cultural Artefact now, in advance of the Ivory Bill coming into force (acknowledging that the value for Cultural Artefacts is currently low in the UK due to the announcement of the proposed Ivory Ban), or to keep these items knowing that they will never be permitted to sell them, even in times of financial hardship. Further, as the insurance value for artworks and artefacts is largely based on the current market value, once the Ivory Bill is in force and the market value for Cultural Artefacts that do not meet an exemption is zero, those individuals who have made the decision not to sell their Cultural Artefacts will run the risk that should their heirlooms be damaged or stolen, they may be unable to claim on their insurance.

7.3 It is well established that is unlawful for a public authority to act in any way which is incompatible with Art 1 (1st Protocol) of the ECHR. [22] Whilst this right is a qualified right, a public authority is only able to interfere with that right if that interference is justified. In order to demonstrate that the interference is justified, the interference must be "proportionate" to the legitimate aim pursued.

7.4 It is also well established that in order to demonstrate that interference with a human right is indeed proportionate, (i) the interference must be rationally connected to the objective sought; and (ii) the interference must be no more than is necessary to accomplish the Objective. On the basis that there does not appear to be any evidence that the trade in Cultural Artefacts contributes to the ivory poaching, and on the basis that there appears to be no distinction between the Government’s rationale for granting the exemptions for musical instruments and portrait miniatures and further having regard for the measures that could easily be implemented to ensure compliance with a date based system, we respectfully submit that such interference is not proportionate to the Objective and is therefore an unlawful interference with the right to property.

12 June 2018

ANNEX

Exemption for outstandingly valuable and important pre-19471918 worked specimens items

2 Pre-19471918 worked specimens items of outstanding artistic etc value and importance

(1) An item that is made of ivory, or has ivory in it, is exempt from the prohibition if-

(a) the Secretary of State has issued a certificate under this section (an "exemption certificate"), and

(b) the certificate has not been revoked under section 4(3).

This is subject to section 4(7).

(2) The Secretary of State may issue an exemption certificate for an item only if satisfied that-

(a) the item is a worked specimen pre-1918, and

(b) the item is of outstandingly high artistic, cultural or historical value became a worked specimen pre-1947 and has not been materially altered since 1947.

(3) The following matters are to be taken into account in considering whether the condition in paragraph (b) of subsection (2) is satisfied in the case of a particular item-

(a) any documentary evidence of acquisition pre-1947 the rarity of the item;

(b) any scholarly evidence indicative of age the extent to which the item is an important example of its type;

(c) any other matters specified in guidance issued by the Secretary of State.

(4) An exemption certificate for an item may be issued only on the application of the owner of the item.

(5) The Secretary of State may by regulations prescribe institutions and/or individuals that, in his or her opinion, possess the necessary knowledge and expertise to provide the Secretary of State with advice on applications for exemption certificates.

In this Act "prescribed institution" means an institution or individual prescribed under this subsection.

(6) An institution may be prescribed under subsection (5) only with the consent of the persons in charge of the institution.

36 Meaning of other expressions

(1) In this Act-

"accredited civilian officer" has the meaning given by section 17(7);

"the appropriate court" has the meaning given by section 29(8);

"dealing" has the meaning given by section 1(2) to (4);

"designated customs official" means a person-

(a) designated as a general customs official under section 3(1) of the
Borders, Citizenship and Immigration Act 2009, or

(b) designated as a customs revenue official under section 11(1) of
that Act;

"designated NCA officer" means a National Crime Agency officer
designated under section 10 of the Crime and Courts Act 2013 as a
person having either or both of the following-

(a) the powers and privileges of a constable;

(b) the powers of an officer of Revenue and Customs;

"exemption certificate" has the meaning given by section 2(1);

"justice" means-

(a) in England and Wales, a justice of the peace;

(b) in Scotland, a sheriff or summary sheriff or a justice of the peace;

(c) in Northern Ireland, a lay magistrate;

"police officer" has the meaning given by section 29(8);

"police or customs officer" has the meaning given by section 14(4);

"pre-1918", "pre-1947" and "pre-1975" are to be read in accordance with subsections (2) and (3);

"premises" has the meaning given by section 17(7);

"prescribed institution" has the meaning given by section 2(5);

"the prohibition" means the prohibition in section 1;

"relevant evidence" has the meaning given by 14(4);

"relevant offence" has the meaning given by 14(4);

"search warrant" means a warrant under section 18;

"vessel" is to be read in accordance with subsection (4);

"worked specimen" means a specimen of ivory that was significantly altered from its natural or raw state for jewellery, adornment, art, utility or musical instruments, pre-1947 and that has been acquired in such conditions. Such a specimen shall be considered as worked only if it is clearly in one of the aforementioned categories and requires no further carving, crafting or manufacture to effect its purpose.

 

[1] "Cultural Artefacts" means pre-1947 worked or carved artefacts which is a specimen of ivory that was significantly altered from its natural or raw state for jewellery, adornment, art, utility or musical instruments, pre-1947 and that has been acquired in such conditions. Such a specimen shall be considered as worked only if it is clearly in one of the aforementioned categories and requires no further carving, crafting or manufacture to effect its purpose.

[1]

[2] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 96

[3] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 96

[4] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 96

[5] The NGOs include The Environmental Investigation Agency, Stop Ivory, The David Shepherd Wildlife Foundation, The Wildlife Conservation Society, The Zoological Society of London, Born Free Foundation, Natural Resources Defense Council, the World Wildlife Fund, International Fund for Animal Welfare and Tusk Trust, see Summary of responses and Government response to the Consultation on proposals to ban UK sales of ivory dated 3 April 2018; Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Columns 100, 120

[6] Martin Levy, ‘Forum: Is the US ivory ban counter-productive?’ Apollo, June 2014: https://www.apollo-magazine.com/forum-us-ivory-ban-counter-productive/ (published online, 9 June 2014).

[7] The European Convention for the Protection of Human Rights and Fundamental Freedoms Article 1 of the First Protocol ("Art 1 (1st Protocol)"), natural and legal persons have a right to the peaceful enjoyment of their possessions. Section 1(1) of the Human Rights Act 1998 ("HRA 1998")

[7]

[8] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 100. Sue Hayman MP supported the WWF in arguing that exemptions were necessary.

[9] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 120

[10] Summary of responses and Government response to the Consultation on proposals to ban UK sales of ivory, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/696474/banning-ivory-consult-sum-resp.pdf , page 19

[11] Summary of responses and Government response to the Consultation on proposals to ban UK sales of ivory, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/696474/banning-ivory-consult-sum-resp.pdf , page 13

[12] Summary of responses and Government response to the Consultation on proposals to ban UK sales of ivory, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/696474/banning-ivory-consult-sum-resp.pdf , page 16

[13] Summary of responses and Government response to the Consultation on proposals to ban UK sales of ivory, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/696474/banning-ivory-consult-sum-resp.pdf , page 12

[14] https://www.thefanmuseum.org.uk/collections/search?eHive_query=Ivory

[15] https://www.ashmolean.org/islamic-middle-east

[16] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 96

[17] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 102

[18] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 95

[19] Second Reading of the Ivory Bill, House of Commons, 4 June 2018, https://hansard.parliament.uk/commons/2018-06-04/debates/209B22F2-123F-4CEF-B6DC-A1A7B0AAC755/IvoryBill, Column 95

[20] Summary of responses and Government response to the Consultation on proposals to ban UK sales of ivory, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/696474/banning-ivory-consult-sum-resp.pdf , page 13

[21] from: Collins, A., Cox, C., & Pamment , N. (2017). Culture, conservation and crime: regulating ivory markets for antiques and crafts. Ecological Economics, 135, 186-19

[22] The European Convention for the Protection of Human Rights and Fundamental Freedoms

 

Prepared 14th June 2018