SUMMER 2022 IS THE RIGHT TIME TO ADDRESS CITES’ problems and opportunities. Several strands in our work show that the 2019 CITES Conference of the Parties (CoP18) saw a worsening of many of the nearly half-century of enfeebling trends in its deliberations. We need to make sure that the next CITES CoP (CoP19 in November 2022) rescues this vital body from the subversive influences that have come to dominate it.
Wildlife Betrayed shows how many of CITES’ Parties and well-funded animal activist groups have betrayed the wildlife for which they declare a great passion.
The name behind the acronym proclaims that CITES is the Convention on International Trade in Endangered Species of Wild Fauna and Flora. Since 1973 it has been flagged and tasked as the leading regulatory body within the international rules-based order as it applies to the threat of wildlife extinctions in which international trade is an important factor.
To its credit, CITES adopted the mantra of sustainable human development in the 1990s. But as CITES approaches its 50th anniversary, there is a war being fought over what it exists to achieve. We believe that modern populist conservation thinking is obsessed with the idea than humans have no role in nature except to stand back in awe. On the contrary, we insist that the excellent conservation goal of sustaining wildlife abundance can be achieved, but usually involves human intervention. Thriving African elephant populations, for instance, at this moment are damaging their dryland habitats. Our ‘perfect planet’ needs human management. Our mission is to promote what the jargon calls CWU: Consumptive Wildlife Utilisation.
We insist that CWU can be invaluable for conservation and sustainable development. We believe many Westerners and UN-related bodies now under-rate the value of CWU, especially when it comes to managing or killing wild animals (unless they are fish, and even for that support is weakening).
CITES’ foundational texts allow and assume a role for CWU, including managing and killing animals. This makes this UN-allied body potentially invaluable in what is a hostile media, academic and regulatory environment.
Ours is positive work: we propose reforms which could ensure CITES a vibrant future within sustainable development, wildlife management, and the rules-based international order.
Our proposals go with the flow of modern thinking: they aim to deliver many of CITES’ own evolving aspirations, as revealed in its Strategic Vision: 2021-2030 (2019). They also contribute to modern thinking about evaluating the true economic value of ecosystem services. We do not at all ignore the way nature has an extraordinary aesthetic and emotional value, differently experienced by different people, and therefore contested.
We are very aware that every multi-national, international ambition requires buy-in from nation states. Inevitably, varieties of self-interest bedevil humanity’s progress in such matters. This is the underlying truth of all Multilateral Environmental Agreements (MEA).
IWMC World Conservation Trust (IWMC), aka integrating wildlife, markets & conservation, maintains that the idea of the ‘Global Commons’ for biodiversity or species, fondly idealised by many, cannot be made real by wishful thinking but only by nation states.
The flow of the book
Wildlife Betrayed is divided into four sections: first extensive introductory remarks about the book’s contents and core messages, of which this explanation forms but a part, that also provides an outline of what CITES is about, and explains how it is organised and funded; an examination of the Multilateral Game and where and how NGOs and CITES fit in; six in-depth case studies, plus a call for the reform of CITES; and our concluding remarks.
THE MULTILATERAL GAME
The Multilateral Game section of Wildlife Betrayed provides an analysis of the post-second world war multilateral framework of which CITES is a pillar. It also unpicks the ‘ocean-grab’ ambitions of many leading environmental NGOs and illuminates
the dilemmas which lie behind their favoured rubric, ‘the Common Heritage of Humankind’. It describes how the precautionary principle and the rights and causes of those living closest to wildlife have been abused and appropriated by NGOs for other purposes. It further explores how CITES has been exploited to undermine and circumvent the authority of the Food and Agricultural Organization (FAO) and regional fisheries management bodies.
The penultimate chapter of this section focuses on some of the activities and beliefs of the NGO thought leaders which dominate CITES ideologically and operationally. Then ‘WWF: pandering to the squeamish’ concludes this section by highlighting how the World Wildlife Fund (WWF) helped initiate and still supports Zimbabwe’s Campfire, which was from the outset an inspiring, courageous community-based natural resource management (CBNRM) scheme. This demonstrates two things. First, that environmental NGOs do sometimes make a positive contribution. Second, that their fundraisers, bureaucratic and public relations cadre often undermine the best work of their own institutions.
THE CASE STUDIES AND A CALL FOR REFORM
The Case Studies show how several groups of species that CITES Parties (its signatory nations) listed in the Appendices were arrived at by flawed deliberations and debate.
Our six Case Study species were chosen to feature both CITES’ weaknesses and strengths, but also the extraordinary difficulties it faces.
The Introduction to the Case Studies is a guide to the author’s approach to nomenclature: why, for instance, he likes to use the words ‘prohibitionist’ and ‘Listocratic’ when describing many campaign NGOs.
Covid-19 and CITES shows how the Convention is at risk of barking up the wrong tree as some campaigners seek to turn it into a police force. Their approach to Covid breaches several of CITES’ core principles. It seeks to deploy the Convention in a case where there is no threat of extinction to wildlife; there’s no science or evidence to support their demands; and it poses a clear threat to the sovereignty of CITES’ Parties.
Whales: harvest or media icon? shows how, right from the start in 1975, the good intentions of sustainable use old-school conservationists were hijacked and subverted by a new wave of militant animal activist bodies that launched a culture war, which attracted some seemingly unlikely governmental allies.
The Oceans and its sharks, tuna and eels discusses a far greater economic issue, and a much more complicated range of over-exploitations and solutions. After all, it concerns a very diverse resource spread across and throughout–or under–over 70 percent of the world’s surface, and one which helps feed billions of people. Here we raise concerns about how the over-exploitation of some aquatic species or of their sub-populations is hyped as a general threat of multiple extinctions. Luckily, there are several other UN and allied bodies which are better equipped to deal with these matters, though they face formidable challenges in the real world. The African savannah elephant case study recounts key elements in the battle between two competing models for conservation of the species. It is a textbook example of the conceptual and practical differences in the culture war between pragmatic and prohibitionist approaches. It is also a controversy that could split CITES apart or render it impotent in the near to medium future.
Rainforests and the rosewoods explores a problem which first surfaces in the earlier Elephants and Oceans case studies but arises in even sharper form in these terrestrial, tropical habitats. How successfully, or rightfully, can huge tracts of territory be declared ‘no-go’ areas, with the purist ‘hands-off’ approach to human exploitation which is favoured by ‘prohibitionist’ NGOs?
We look at evidence which suggests that, without underestimating the curse of corruption, only sovereign governments can determine and implement forest policy, and that some are doing so with a degree of success.
We also turn to the rosewoods issue to reveal the nimbleness of criminals as they evaded CITES’ regulations, ran out of the easiest stocks, and sought more and more lookalike species from poorly regulated range states.
Vicuña and the crocodilians details two cases of sustainable use and how international trade ameliorated the condition of threatened wildlife. It shows also how the interest of CITES in an extinction threat can reap positive results. Though having said that we acknowledge that CITES was not necessarily the force for good here.
Taking back control concludes this section by diagnosing what ails CITES in its current form. We say its deliberations are clumsy; it is obscure in its decision-making; it is reticent in dealing with the outside world; and it is dated because it was conceived before the arrival of many other (‘rival’) UN and allied eco-Conventions. Our proposals see it slimming down; operating as far as possible in plain language; and starting a new communications venture. We also propose that CITES should be able both (a) to accept that a particular species is threatened with extinction, with international trade as a factor, and list it and/or refuse to do so while (b) insisting that it is not necessarily the most appropriate or qualified regulatory body involved in protecting that species.
It is vital, we say, that CITES reviews and debates in detail its failures and successes and that it adjusts its listings in the Appendices to reflect what it learns from this cathartic exercise.
We envision CITES as commissioning accessible, transparent, well-evidenced Comprehensive Reviews of what and who threatens–and what and who may help–species endangered by trade. These Reviews would support the consideration of proposed listings and assess the efficacy of existing ones.
Crucially, we propose a Code of Conduct for (designated observer) Participants. We argue that contributions to CITES’ processes and debates of any sort, from anywhere, would not be ‘CITES-compliant’ if the Participant started from a premise that sustainable use was intrinsically a Bad Thing.
Why no rhinos? Why no India?
We have been highly selective in the species we cover. There is little here on giraffes, tigers, lions, or orchids–or any others of the thousands of species listed by CITES. We have chosen a few cases, in the belief that a few well-discussed examples illuminate our themes better than many being merely glanced-at.
CITES and the Culture Wars
A substantial majority of the world’s human population are content that animals and plants, domesticated or wild, are managed and harvested for our use. CITES works within that general proposition; not in opposition to it. Of course, all such exploitation must be sustainable; a term which is rightly taken to be open to animal welfare concerns.
There is today an increasingly intense debate between those who endorse that pragmatic approach and those who want to shut down the wildlife trade. A kind of militant romanticism is in the air, and it does not seek merely to make vegan products easy to obtain or to outlaw the hunting of some species or to curtail specific forms of ‘hands-on’ habitat management in some nation states. Increasingly it seeks to penalise or ban wildlife-use practices anywhere and nearly everywhere in the world. A sense of Woke moral superiority, combined with a Citizen of the World belief in a superficial view of the Global Commons, gives such militants an inner certainty which frees them from the need to be bounded by ‘mere’ national sovereignty.
Earlier forms of this borderless campaigning have always been a powerful force within CITES, especially in relation to whaling and the ivory trade, but newer varieties are growing in strength outside and within it. We respect the campaigners’ commitment but criticise their disdain for opposing arguments and the chicanery they have indulged in to dominate the terms of debate.
CITES is a regulatory trade body which is too widely assumed to be, and often behaves as though it were, a prohibitionist one. Yet it is too distant and weak to be a serious regulator. It has neither the funds to do much on the ground, nor the constitutional authority or ambition to compel its Parties–who are responsible for implementation at the national level–to do so.
But CITES has one hidden and unlikely asset which was not envisaged by the Convention’s authors. CITES is the vital if at present inadequate forum for hosting this huge overarching conservation row–a collision and a stand-off. On the one hand, there are the pragmatic proponents of sustainable use, including for international trade. On the other hand, there are the prohibitionist campaigners, who brilliantly present themselves as passionate crusaders untainted by conformity to narrow commercial or national interests. These conservation rows reflect and represent a wider cultural conflict.
The post-war Baby-Boomers’ children and grandchildren are more prone than their elders to be Woke, squeamish, vegan, and vulnerable to celebrity advocacy on social media. Being remote from wild nature, they are naively in love with it. For them it is the only force which has retained its virginity in what they call the Anthropocene.
The campaigners are rich but affect to be anti-capitalist; they live in orderly and free societies but affect to be dissident. They appear to value a heartfelt T-shirt slogan more than a 30-page document. But they are better educated than any previous generation and it would be a counsel of despair to say they will remain or are immune to reason.
Pragmatic conservation can also hope for but dare not expect immediate support from the young who love to eat wild boar burgers or who thrill to reality TV shows from Alaska’s crab fishing fleet or Tasmania’s lobster fishermen.
Constitutional position of NGOs
Campaigning NGOs are embedded and empowered in the constitution and habits of CITES as in virtually no other Multilateral Environmental Agreement (MEA), except perhaps the International Whaling Commission.
This is our guide to CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora). It is intended to take you to CITES’ own evidence as to its workings: how it defines its work, how it runs its bureaucracy, to whom it is accountable, how it is funded and how it organises the implementation of the rules it makes about species endangered by international trade.
CITES, like all MEAs, is defined by its Constitution (aka its articles of association), the Convention on International Trade in Endangered Species of Wild Fauna and Flora. It was drafted in the late 1960s, signed in 1973, and came into force in 1975.1
The work of CITES is fundamentally under the control of its contractant Parties, which are nation state members of the United Nations (plus the EU).2Its Parties might be said to own and control CITES, but international law has rules as to how treaties and conventions work, so there are quite severe constraints, especially on any actions which might be shown to conflict with the CITES Constitution.
INDEPENDENT MULTILATERALTREATY, NOT A UN BODY
CITES is an independent multilateral treaty between 184 nation states (including the EU) and is thus bound by international law and not by orders from the Secretary-General of the UN. However, the Secretariat of CITES (its paid, professional staff) is based in Geneva, Switzerland, and its budgetary audits are linked to the UN and administered by the UN’s Environment Programme (UNEP) based in Nairobi, Kenya.
One should always remember that any multilateral body such as CITES must assume that its Parties deserve every respect, even when they propose punitive and arguably unjustified penalties on member states for noncompliance. So, CITES has never allowed any public announcement to escape its lips or press office which might lead the public to think that any of its Parties are less than good and wise, though it is sometimes admits that some states need help to become more effective in implementing conservation measures.
CITES, ITS PARTIES AND THE NGOS
The CITES Convention, like all the Multilateral Environmental Agreements (MEAs) enshrines the rights of civil society NGOs in its deliberations.3
CITES has always been the venue where the fate of the animal kingdom seemed to be up for discussion, even if the expectations it set fell short. It was also where prohibitionist NGOs (as Wildlife Betrayed dubs them) and prohibitionist animal welfare activists (ditto) gather, by CITES’ own invitation, to make their mark. The
Convention on Biological Diversity (CBD) 1992 was designed to be much more focused on the plant kingdom. It wasn’t quite so free and easy with the campaigning NGOs, either. But the point is that CITES has been and looks set to remain the NGOs’ bear-pit of choice.
THE CONVENTION HAS SIX MAJOR ROLES
1/ CITES lists in its Appendices species which international trade threatens or might soon threaten with extinction. (See below for more on the Appendices.) Arguably it can also list species which international trade threatens with serious diminution anywhere in their range. (See above and below for more on this.)
2/ CITES can threaten and impose trade sanctions on signatory countries which do not obey the rules which the Appendices impose.
3/ CITES can instigate research programmes to monitor international trade (legal and illegal) in endangered species, but it must raise special funds to do so. (See CITES Funding for more on that.)
4/ CITES can encourage other agencies to fund poor countries to implement CITES rules. This is called ‘capacity building’.
5/ CITES can sponsor delegates from poor countries to attend the Conferences of the Parties (CoPs) which are the senior decision-making bodies of CITES.
6/ CITES can partner with other bodies to deploy synergies and avoid wasted overlaps and competition.4
CITES IS NOT JUST ABOUT EXTINCTIONS
To be eligible to be one of the 38,700 species–including roughly 5,950 species of animals and 32,800 species of plants–which CITES has listed in one or other of its Appendices, a species has neither to be on the brink of extinction nor wholly dependent on being listed for its survival. CITES’ rules for Appendix II state that it wants good things for wildlife in a much broader way than is often supposed. Article IV, section 3, applies:
“A Scientific Authority in each Party shall monitor both the export permits granted by that State for specimens of species included in Appendix II and the actual exports of such specimens. Whenever a Scientific Authority determines that the export of specimens of any such species should be limited in order to maintain that species throughout its range at a level consistent with its role in the ecosystems in which it occurs and well above the level at which that species might become eligible for inclusion in Appendix I, the Scientific Authority shall advise the appropriate Management Authority of suitable measures to be taken to limit the grant of export permits for specimens of that species.” (Editor’s italics.)5
CITES IS OPEN-MINDED ABOUTWILDLIFE UTILISATION
Article II, Section 2(a) applies: “Appendix II shall include: … all species which although not necessarily now threatened with extinction may become so unless trade in specimens of such species is subject to strict regulation in order to avoid utilization incompatible with their survival; ….” (Editor’s italics.)
CITES is bound by its Convention text, which can be amended only with great difficulty. It has, however, over the years adopted an evolving Strategic Vision which aligns CITES with the aims of other MEAs such as the Convention on Biological Diversity (CBD). This is how CITES shows (or persuades itself and others) that it is keeping up with the modern trends in conservation, especially sustainable development, consistent with its Convention’s Articles.6
CITES NEEDS TO BE GOOD AT COOPERATION
CITES has practical, administrative, political and ideological reasons to be as well-aligned as possible with the wider UN family, and especially with its fellow MEAs, not least the World Trade Organization (WTO), because of their overlapping conservation and trade roles. CITES has forged significant co-operative arrangements:
CITES has quite formal co-operative arrangements with important allies in the MEA world and beyond
CITES/UN Food and Agriculture Organization (FAO) Memorandum of Understanding (MoU)
CITES/World Trade Organization (WTO) MoU CITES/Convention on Biological Diversity (CBD) MoU
CITES/UN Office on Drugs and Crime (UNODC)/International Consortium on Combating Wildlife Crime (ICCWC), et al., letter of understanding.7
THE ORGANISATION OF CITES’ WORK
The Conference of the Parties (CoP) is the ‘Parliament’ or ‘Congress’ of CITES: it is where the Parties make decisions, not least in providing the mandate and scrutiny of the Convention’s Secretariat and providing top-level oversight of its three main committees which, through the Secretariat, do CITES’ work: Standing Committee, the Animals and Plants Committees (more below).
In December 2020, the Secretariat based in Geneva, Switzerland, was composed of 37 staff. CITES’ Secretary-General has a dual reporting line to the CoP through its Standing Committee and to the United Nations Environment Programme (UNEP) Executive Director. The Secretary-General is the main spokesperson of the organisation and can, up to a point, set its tone and even its agenda. To be effective, the Secretariat must rely on the goodwill and dedication of an army of experts from the member states, many of them unfunded volunteers, who constitute the CITES committees.
There are three committees that enable the Convention and Secretariat to operate, and to advise the Parties on what actions to take. The committees’ crucial and nearly impossible task is to know what species CITES should in theory list, and what real-world good and bad consequences would or could or do flow from doing so. Very often, what the CoP wants doing requires technical, scientific knowledge about either animals or plants. This work is carried out by the Animals Committee and the Plants Committee.8 However, it is the Standing Committee that is the organisational powerhouse of the CITES operation because it has a delegated supervisory role above the Secretariat and is directly accountable to the CoP.9
THE APPENDIX SYSTEM
The CITES Appendix system only sounds simple if it’s being explained wrongly. Explained in full (as its mother ship web pages show10) it’s a nightmare of complexity. The whole thing would challenge a medieval theologian accustomed to wondering how many angels can dance on the end of a pin. As simply as we dare, here is a working account of how the system works.
There are three Appendices, numbered accordingly. Appendix I is the strictest, Appendix II is less strict, and Appendix III applies only when an individual nation asks the others to respect a particular issue it has with a species.
A listing in Appendix I is often and wrongly assumed to be a ban on international trade in a particular species. Quite often it merely insists that the Parties involved in the trade of threatened species set a high bar in their scrutiny and control of the effects of any such trade.
A listing on Appendix II is often and wrongly assumed to be quite like a ban, or at the least a signal of strong disapproval of international trade in a species. It is no such thing. It is intended to be an important signal that a species is at risk of being threatened by unconstrained international trade which therefore needs to reform itself either to eliminate its threat or become a boon to the species. It imposes some very testing regulations: for instance, a producer has to complete and submit Non-Detrimental Findings (NDF).
NDFs are daunting even for sophisticated producers and present a temptation for the less sophisticated or less scrupulous producers to cut corners or manufacture fraudulent documentation. (Apropos WildlifeBetrayed’s Case Studies, NDFs bedevil the implementation of hard to implement CITES listings, especially for eels, sharks and rosewoods.)
A listing on Appendix III is generally much less controversial since it merely signals that a nation state needs other nations to have regard to a conservation concern in its own territory or waters.
The proposed inclusion (or the continuation or removal) of a species on Appendix I or Appendix II can be hugely controversial if influential opinion is divided on the matter, which is very often the case. The divisions are usually about three issues. Is the species threatened sufficiently by international trade to meet the Convention’s definitions? Would a listing produce the desired effect, or would it backfire (perhaps by encouraging illegal trade)? And: can or will the nations involved implement the CITES’ ruling, in the real world?
The operation of Appendix I and Appendix II is made more complicated by the number of exceptions and conditions which apply. For instance, any nation can agree and must respect a listing as it applies to other nations, but they can also ‘enter a reservation’ such that the listing does not apply to itself.
Also: one population of a species may be listed in one Appendix whilst another population of the same species may be in another Appendix or not in one at all. Also (amongst other discrepancies) how CITES defines ‘trade’ means that Trophy Hunting for, say, elephant ivory (which is an international commercial operation) is allowed under Appendix I, but international trade in ivory is not.
These discrepancies and apparent paradoxes are hard to understand, even for those involved with CITES’ day-to-day operations. This creates room for a range of interpretations regarding their meaning, which opens the door to abuse based on willful or mistaken interpretations.
FUNDING AND FINANCIAL MISMANAGEMENT
CITES describes its income from signatory Parties not as their subscriptions but as ‘contributions’ to its Core Trust Fund (or CTL), which amounts (when collected) to just over USD6 million per annum. Additional voluntary extrabudgetary contributions can also be provided to the CITES External Trust Fund (QTL) which finances specific projects.
The Parties’ contributions are assessed according to a UN scale of fees which are kept low for poor countries. But many of the poorest, but also some not-so-poor countries, are in arrears with their CITES contributions, some chronically so.
The management of CITES’ budgets is the responsibility of the Secretariat, overseen by the Standing Committee which is accountable to the CoP. In the three-year period 2020 to 2022, CITES’ estimated budget totaled USD50 million, of which USD30 million came from voluntary QTL contributions from donors (by far the largest of which is the EU) and the rest from assessed contributions applicable to member states.11
In November 2021, an audit of CITES’ financial management by the UN’s Office of Internal Oversight Services (OIOS) found that of the 22 NGO partners it reviewed, which had been hired by the CITES Secretariat to provide services to implement CoP decisions, all of them had been appointed without being subjected to a pre-appointment competitive bid and assessment process.
In other words, the Secretariat should have sought at least three competitive bids. But it had merely granted contracts to its preferred NGO partners without carrying out any due diligence to assess their capacity and suitability to implement projects. The report added that ‘there was no assurance that the Secretariat had engaged the most appropriate implementing partners’, and the delays to projects was a consequence of ‘‘partners’ [aka NGOs] incapacity to effectively implement the projects entrusted to them by the Secretariat’.
Out of 50 reports of the work of CITES’ implementing partners that OIOS reviewed, it found that there was delayed implementation and reporting in 22 of them. Unfortunately, the report did not say whether these 22 delayed projects (none of which it described in detail) were managed by the same 22 NGOs that had been appointed without being subjected to due diligence. However, the report did single out for criticism the Monitoring the Illegal Killing of Elephants (MIKE) programme managed by IUCN. OIOS revealed how CITES itself had discovered a questionable USD1.2 million expenditure by MIKE that resulted from the misapplication of procurement procedures, and for which there was inadequate documentation. Moreover, according to OIOS, MIKE’s financial reporting was ‘periodic, as well as inadequate’.
When assessing how CoP decisions were implemented by fully funded programmes of work (PoW), OIOS found that the CITES Secretariat neither tracked nor reported on their progress nor measured PoW achievements. Moreover, out of 28 partner projects that should have been audited by CITES itself, the Secretariat could only show OIOS two that had been completed.12 13
1 Along with a handy historical note, the Convention text is here: https://cites.org/eng/ disc/what.php Accessed 02/03/2022
2 See: https://cites.org/eng/disc/parties/chronolo.php Accessed 02/03/2022
3 Article XI Section 7 applies See: https://cites.org/eng/disc/text.php#X Accessed 02/03/2022
4 See: https://cites.org/eng/disc/sec/index.php Accessed 11/07/2021
5 See: https://cites.org/eng/disc/text.php#IV Accessed 02/03/2022
6 See: https://cites.org/eng/documents/Strategic_vision Accessed 02/03/2022
7 See: https://cites.org/sites/default/files/eng/disc/sec/FAO-CITES-e.pdf and https:// cites.org/sites/default/files/eng/com/sc/55/E55-09.pdf and https://www.cbd.int/ doc/nbsap/CITES-NBSAP-Module.pdf and https://cites.org/eng/UNODC_releases_ WorldWildlifeCrimeReport2020_CITES_10072020 Accessed 02/03/2022
8 See: https://cites.org/eng/disc/ac_pc.php Accessed 02/03/2022
9 See for details on the CITES Standing Committee: https://cites.org/eng/disc/sc.php Accessed 02/03/2022
10 See the CITES Appendix system where it is explained formally: https://cites.org/eng/ app/index.php
See, for the Appendix listings in full: https://cites.org/eng/app/appendices.php Accessed 02/03/2022
11 See https://cites.org/sites/default/files/eng/res/18/E-Res-18-01-A1.pdf Accessed 06/05/2022
12This job advertisement for a leadership position in the MIKE programme provides an overview of IUCN’s regional responsibilities in Africa. See: www.iucn.org/sites/dev/files/import/downloads/2008_09_mike_sub_regional_support_officer.pdf Accessed 02/03/2022
13 The audit concluded that CITES needs to strengthen internal controls in the areas of strategic management, operations, finance and administration. Among the core recommendations was that NGOs must be subjected to due diligence before being appointed as implementing partners to manage projects. Another was that that the process of awarding contracts must be competitive and once appointed implementing partners must submit regular reports. Furthermore, any potential renewals of contracts should be assessed based on a properly documented evaluation of their performance. https://cites.org/sites/default/files/eng/disc/funds/2021_051%20final%20report.pdf Accessed 03/03/2022