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Ian Parker Collection of East African Wildlife Conservation: The Ivory Trade

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Title:
Ian Parker Collection of East African Wildlife Conservation: The Ivory Trade
Uniform Title:
A Background to the Ivory Trade.
Alternate Title:
White Report
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Parker, Ian.S.C.
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Preferred Citation:
Parker, I. [Ian] S.C. 1973. A Background to the Ivory Trade. A confidential report made at the request of J.Block, Esq.” [The so-called “White Report” due to the color of its original cover]. Available: http://ufdc.ufl.edu/AA00020117/00016.

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A BACK(GROUMD TO TE IVORY YR\, 'km







A CONFIDENT ..L REPORT MADE AT THE REQUEST OF
J. BLOCK ESO.,













OCTOBER 1973
f
















I.S.C. Parker
Wildlife Services Lta..
P. O. Box 30678.
Nairobi.
Kenya.











2
IVORY A CURRENCY


An article is of value if made of ivory. Ivory is not of value because

certain things are made from it. In this respect it is like gold and the

reasons why men have chosen both with a very limited range of other

materials, as criteria of wealth through the ages have yet to be explained.



Elephant tusks do not bear the seal or stamp of any one nation, are

difficult to identify as to nationality, and thus freely negotiable. With the

exception of perhaps four of the smallest states in West Africa and Burundi,

all countries south of the Sahara have elephant populations and are ivory

producers. It is thus an "African" currency, and as "hard" as gold or

gems. it is widely used In barter in many countries and I have personal

experience of it being used to purchase vehicles, and discussed as a means

of payment for a large cement contract at Government levels.



I have not had time to assemble all data a-rlable to determine how many

tusks leave Africa annually. However it seems probable that it is in excess

of 200, 000 (100, 000 elephants) and may even be as high as 400, 000. The

average weight of tusk exported is not yet known. It will almost certainly










3

be in excess of 4.5 kilos and could easily be 9.0 kilos. If this is the

case the gross value of the continent's ivory exports will be between

US $72, 000, 000 and $144, 000, 000 annually. Even if actual exports are

only half the lower postulated figure, the volume is still "big money" in

anyone's language.



Ivory is durable. Though made into articles it is not "consumed".

Year by year stocks accumulate and actual quantities In "circulation" must

vastly exceed any one year's production.. This accumulated stock

represents investments that run to at least hundreds of millions of dollars.

With this perspective the management of the ivory trade is more the

concern of international banking and government finance ministries, rather

than game departments.



The 1925 average value for East African Ivory was Sh 37.00 per kilo.

Had this grown in accordance with general Inflation at 10% annually over the

intervening years, Ivory value today would be Sh 3, 663.00 a kilo. This has

not happened. The actual trends in value between 1925 and 1973 are given

In Table 1 and Figure 1.










4

TA13LE 1 Average annual values in Shillings per kilo for East African
ivory exports 1925 1973.

1925 37.65 1949 23.32

26 31.63 1950 23.90

27 30.69 51 27.80

28 29.43 52 28.13

29 26.72 53 30.51

1930 21.23 54 21.98

31 7.50 55 32.05

32 17.17 56 33.40

33 13.18 57 32.78

34 13.18 58 31.30

35 14.09 59 29.50

36 12.37 1960 34.76

37 15.10 61 32.85

38 12.54 62 30.16

39 12.23 63 34.43

1940 13.65 64 38.67

41 12.85 65 44.29

42 15.52 66 42.26

43 20.39 67 43.36

44 20.22 68 38.84

45 21.58 69 40.14

46 25.33 1970 56.48

47 25.66 71 67.30

48 22.22 72 68.46

1973 233.36 (US$33.82)

















280-

260-
0

240 4
H

220-
2oI.
20~L
L
180. '

L
160.;.
I
140..
N,'
120-

GIOQ..

S
80_

60 .. /

40 '/'*-

20 ,---,. .._ ., '

.......... .. ... ... ... ... 8 "
166 1930 1940 1950 1960 1970 1D73
T I M E


FIG. 1 Average East African Ivory Values 1925 1973
against a curve representing 8% annual Increase.










6

From these It may be seen that there have been three major trends

1) A continuous fall in value from 1925 until 1936, which coincided

with the onset and duration of the great economic depression of the

.1930s.

ii) A gradual rise at approximately 4.5% annually until 1969, and

111) Very sharp rises In value 1970 1973 averaging 75% in each year.



The first of these trends seems to be the direct product of the Depression

and it appears that It led to ivory being re-valued. If we take the 1936 price

of Sh 12.37 per kilo as a starting point, and extrapolate a 10% growth rate

from 1936 until 1973, ivory should be worth Sh 419.98 per kilo today

(US $60.95). This price has been attained repeatedly on the International

ivory markets this year, suggesting that growth In value has been the

expected. However the East African Customs data for the first six months

of this year indicates an average value of Sh 233.36 per kilo. If this is a

genuine figure, growth over the years since 1936 has been slightly over

8% annually. I believe this to be incorrect and a reflection of illicit

ourrenoy moves.










7

The second trend in ivory values which lasted from 1936 until 1969,

Indicates a lower annual gain than was to be expected. I feel this is a

result of a deliberate buying policy by the major traders acting in concert,

rather than genuinely slow appreciation in values. For example, it has

never been reflected in East African values that calasia Ivory (a commercial

grade) was selling In India at Sh 132.00 per dlo in 1965. Further evidence

of artefact is the differences in prices paid between different regions of

Africa. While a certain quality may have raised Sh 33.00 per kilo In Kenya,

It would only attract Sh 16.00 in Southern Africa. However once buyers

with recent East African experience bought in the south, values equalised

to the East African levels. Such a situation was possible through the

Africantxad,, dmination by a relatively small group of Asians. The

over-riding advantage of such a policy would have been stabilisation of

production In the same manner that De Beers Influence diamond sales and

prices. It would also have permitted concealment of Income and thus fairly

massive evasion of tax. Since Independence in many African States, there

has also been an escalating desire by aliens to extract capital from them

Illegally. Depressed ivory prices provided ample cover for this. Over

the period 1936 1969, the difference between the expected 10% annual









8

appreciation of ivory value and the actual annual rise of 4.5%, may reflect

the sum of tax evasion and concealed currency movements that have taken

place. If this is so, the amount is considerable.



The third trend apparent in the data in Table 1 and Figure 1 represents

a rapid rise from the depressed prices that prevailed until 1969 to the real

values that are the product of 10% annual inflation since 1936. These rises

have coincided with growing monetary instability and major declines in

the value of the US Dollar. Widespread uncertainty in "national currencies"

led to an urge to Invest In "international currencies" ivory and gold etc.

This drive has been particularly strong in the East. Normal channels were

unable to meet demand and speculators started widespread buying at source

- in Africa. Even at Government levels there has been support for this

approach. An example:

The Japanese Government has stocks of US Dollars that threaten to devalue

considerably and therefore wished to "dump" them. African countries need

"hard" currency, no matter how Ide-valued" It may be, and are therefore

prime "dumping" grounds. Most have, in addition, substantial trade

imbalances with Japan. Rather than pay the real value to the middlemen in










9

Hong Kong, it pays the Japanese to give the full rate to Africa to gain

substantial balance of trade benefit. Japanese, with Government blessing,

thus exchange their dollars for Ivory (to everyone's delight except the

traditional traders). Similarly, substantial quantities of ivory have made

their way to Peking, particularly from Tanzania.



The situation has been given greater complexity by the desire of many

aliens in Africa to extract investment from the continent, or to invest

outside it. This urge has reached a measure of desperation with Asians in

Kenya, but It also includes many prominent Africans in a number of states.

A measure of what may have been kept overseas from Kenya's exports in

the first 6 months of 1973 may be revealed by Customs Department valuation

of these at approximately US $35.00 per kilo. In this period much ivory has

In fact obtained over $60.00 per kilo. On the basis of my personal

experience I think that the. average price for all grades must have been

$45.00 over the 6 months, giving a margin of $10.00 over the Customs value.

If this Is the case proceeds kept outside Kenya will have amounted to

$2, 136, 730 or S 824, 992.27.










10

In conclusion: ivory is currently near its "real" values in Africa.

However speculation in it is wild and erratic. As I write I am aware of a

major London firm trying to sell a consignment of ivory, currently in

Beirut, ex Khartoum, worth miny thousands of dollars, to a company in

Botswana for resale to the Far East no one In the London firm having

seen the consignment or dealt in ivory before. The situation has many of

the chaotic aspects of a gold rush, and it is in Africa's interests to

organise the trade.













KENYA'S IVORY TRADE

The most fundamental and continuous influence on elephant numbers

throughout this century has been human expansion. As people increase

they take up more land displacing elephant that may live on it. This

process Is unavoidable and would continue irrespective of any demand for

ivory. Kenya's domestic Ivory exports over the period 1925 1973 reflect

this process of attrition. The relevant data are presented in Table 2 and

Figure 2. From these it may be seen that the ex ports oscillated around

a growth rate of about 3% annually until 1970. The two major depressions

in the export pattern coincide with the second world war and Mau Mau

emergency respectively. Logically, it appears that these two political

events temporarily slowed output of ivory.



Abrupt Increases commenced in 1971. In that year exports rose by 86%

over the preceding year. In 1972 there was a further increase of 81% over

1971, and the first six months of 1973 saw a further gain of 42% over the

whole of 1972's output.












Kenya's annual exports
1925 1973.


1925

26

27

28

29

1930

31

32

33

34

35

36

37

38

39

1940

41

42

43

44

45

46

47

48


of Domestic ivory in kilograms
I"


16, 303

14, 915

25, 575

14, 899

12, 224

16, 275

13, 280

13, 941

18, 998

21, 162

19, 506

18, 145

15, 877

13, 307

12, 396

11, 126

12, .542

5, 639

5, 839

13, 209

14, 733

34, 751

25, 707

19, 712


1949

1950

51

52

53

54

55

56

57

58

59

1960

61

62

63

64

65

66

67

68

69

1970

71

72

1973


TABLE 2


23, 116

25, 606

22, 507

14, 784

16, 918

15, 741

33, 159

31, 889

23, 905

26, 310

27, 262

29, 261

32, 615

40, 826

42, 096

39, 120

29, 311

45, 213

48, 350

38, 572

33, 388

44, 383

82, 727

150, 305

213, 673 (6 months only)







220-



-13.
200L
FIG. 2 Kenya's Annual Exports in
10Kograms 1925- 1973
1180-:

0

0 4

S 160i.




140.
0

F 3% growth curve
120" '




K 10(L

I 90.. Annual Exports

L
804

70 /

R 60

A 502

M40~
S
30.. (N

207 ... I




... .. .. ..................................... .........
1925 1930 1940 1950 1960 1970 1973
T I M E










14

Examination of export response to increases in value is made for the

period 1925 1973. Figure 3 Illustrates the relationship graphically. It

seems fairly clear that price increases coincide with increases in exports.

The great growth of exports 1971 1973 seems a direct response to the

rocketing local values.



Other than the general export statistics kept by the Customs Department,

there is no composite collection of data relating to the trade in Kenya.

Theoretically, the Game Department should be able to trace the origin of

every tusk legally possessed In Kenya. This Is not the case. Apparently

most of the Department's records prior to 1965 have disappeared and no

annual reports have been issued since 1965. Even the number of animals

shot on control by the Department itself seems subject to dispute.

Nevertheless, despite the absence of accurate data, it Is possible to assemble

a speculative picture of what has been happening.




Let us concentrate on domestic Ivory exports for the first six months of

1973. In this period 213.67 tons were recorded as leaving Kenya. To have

been documented by Customs all this ivory must have been covered by

















FIGURE 3


Changes in values from year to year related to changes

In export volumes 1925 1973.
1925 1962 Total E. A. ivory trade volume

1962 1973 Domestic exports only as imports ceased in 1962


!Export volume


x


I
I


I













I


















1925


1930


1~
I'
, 9


-S I 5


S -



/ Il- \ i' :1




I -I


I /


I
I,


/
/


1940 1950 1960


I.
.... .. /:


197017










16

permits from the Game Department. Legal sources of ivory are limited to:

1) Elephant shot on licence. It would appear from data obtained from

the Department that this source accounted for c.31 tons (14.5% of

total exports).

ii) Game Department control shooting. It is difficult to get figures on

this. Normally the Mombasa auctions provide some Information on

the amount of control work, but in 1973 such ivory appears to have

been disposed of by other means. At the only auction held this year

the Department produced only 0.68 of a ton (0.3% of exports) : 174

tusks averaging 3.9 kilos each (this must be the smallest quantity

auctioned by the Game Department in Mombasa in 60 years). It Is

believed that about 500 elephant were shot on control In 1970 and that

the numbers have not substantially increased since then. If this is

so the six months of our Interest should account for 250 elephant.

Should these provide 27.22 kilos of Ivory each (a generous figure in

view of previous records) control work should have provided 6.8 tons

(3.18% of the 6 months' exports).

III) Natural Mortality. This normally provides a substantial quantity of

ivory for Government. Its absence at the last auction is puzzling.











17

It is also the major source of national parks' ivory and part of the

ivory gathered from the 1971 die-off of elephants in Tsavo was sold

in June. This amounted to 16.9 tons (7.9% of the 6 months' total).

iv) Collectors' Permits. These permits are an innovation that appeared

in the late 1960s. Essentially they are a Chief Game Warden's Permit

(given by that officer at his discretion) allowing an Individual (or group)

to "collect" ivory. Presumably the rationale is to permit the

recovery of "found" ivory (a very good reason as natural mortality

constitutes the largest potential source of ivory in the country.)

However, it would appear that these collectors' permits are responsible

for 163,29 tons (76.4% of the 6 months' exports) out of the 213.67 tons

exported. This may be so, but there is no precedent to suggest that

this could have come from "found" ivory. It would be naive to conclude

anything other than that the collectors' permits have been used as an

extensive cover for illegal ivory trading.



Let us now consider illegal aspects of the trade. There are two major

sources of illicit ivory: internal poaching and the import of ivory from

outside Kenya. In concord with the rising price of ivory, there has been a










18

growing outcry over the amount of elephant poaching taking place in 1973.

In the main reports of this stem from professional hunters and to a lesser

degree from national park wardens. There has been considerable subjective

corroboration of these through the abundance of elephant carcasses sighted

from the air. There can be no doubt therefore that elephant poaching In

Kenya has reached high levels even though it is not possible to place reliable

figures on Its extent.



What Is of considerable importance in this analysis is that though 1971

and 1972 experienced massive increases In ivory exports, there were no

comparable outcries about poaching to that in 1973. This raises the

possibility that at least part of the recent exports came from outside Kenya.

For Kenya to deal in this commodity would be nothing new. Prior to 1962,

Kenya's total ivory exports were comprised of 3 to 4 times as much imported

Ivory as there was domestic production. Mombasa was the biggest entrepot

Ivory centre on the continent outside Zanzibar.



From my trading outside East Africa, I am aware that considerable

quantities of ivory are indeed being sent to Kenya. I was personally











19

approached by two African ivory dealers in Nairobi, both of whom wanted

to buy ivory from outside Kenya. Both scolfed at the Idea that there should

be difficulty In getting any amounts into the country "legally". A Zarean

gentleman offered me a supply of 5 tons a week in Nairobi (ex Zaire).

Similar quantities to this pass through Juba from Zaire weekly, and I have-

no grounds to disbelieve the offer. At least one Nairobi company has handled

substantial quantities of Tanzania ivory this year. Tanzanian hunters openly

admit they send their ivory to Nairobi. Examination of Tanzanian statistics

Indicates that last year 250 tons were exported, but that unlike Kenya, the

values declined from the 1971 level by 20%. (Evidence of a state monopoly

lowering prices out of phase with general trends and thereby creating

Incentive to by-pass it Illegally.) This year Tanzanian exports are down

very steeply indeed, and though the price is up on 1972, it is still well

below Kenya's level. It is certain that quantities of Tanzania Ivory are

coming to Kenya Illegally to take advantage of higher prices hence the

decline In this year's legal exports from that country.



All my evidence indicates that considerable quantities of ivory are

coming Into Kenya from neighboring and nearby states.










20

Finally, to conclude this chapter, I must make some comment on who is

In the trade.



..At the moment Asians are still the largest dealers in ivory. One Nairobi

family alone has accumulated more than 100 tons of ivory in Hong Kong.

Most of them have "shadow" companies In Europe or the Far East who act

as their "buyers". For them It is a major route for getting substantial

quantities of capital away from Africa. There are a few Europeans trying

to enter the trade for the same reasons as the Asians, but these, for the

most part, have been singularly unsuccessful mainly through complete

ignorance of how to set about it However, there is a very rapidly growing

African Involvement In the trade, as has been apparent from the past two

auctions In Mombasa. Some have "gone It alone". Others have entered Into

partnerships with Asians.




The outstanding point is that some of these Africans are of political

consequence. The liaisons they make both Internationally and internally -

may have repercussions beyond the sphere of business, especially if any

Illegality Is Involved. Blackmail becomes a probability.













THOUGHTS ON FUTURE POLICY

I shall summarlse the ground covered so far:

1. Ivory is a currency of International standing that is presently in great

demand. Its value to Afrlca runs to millions of dollars annually, as

well as serving to facilitate inter-state trade. However, the cumulative

quantities outside Africa particularly the Far East represent investments

that must run to at least many hundreds of millions of dollars.

2. There Is no effective management of the resource in Africa. By

demonstration, conservation departments are in Ignorance of the situation

and totally unequipped to handle It. Such control as there has been

appears to have been effected by the Ivory traders themselves

influencing production through prices. Tenuous at the best, this has

been destroyed by instability in the world monetary system and trends

in African politics. Currently elephant management and the ivory trade

Is a scene of chaos and wild speculation.

3. Kenya's exports have soared In response to rising local prices. They

have been used as a major vehicle for transferring capital out of the

country. Funds lost to Kenya in the first six months of 1973 may have

been of the order of US $2, 136, 730.00.












22

4. Kenya's exports of 213.67 tons of ivory In the first six months of 1973

cannot be satisfactorily accounted for by conventional legal sources.

It would appear that the "unconventional" collectors' permits may be

responsible for 76% of exports and are felt to have given cover to

much illegal ivory.

5. The level of poaching in Kenya is currently high, but probably does

not account for the bulk of illegal ivory. This is made up from sources

outside Kenya.

6. There are people of great political consequence In Kenya involved In

the Ivory trade. In view of the enormous sums of money represented

by Ivory, such involvement could have much wider repercussions than

Initially apparent.



There Is an obvious case for the organisation and management of Africa's

Ivory trade. However the subject Is so wide and with such far-reaching

implications that at this stage all one could hope to do would be to obtain

more information and perhaps try to achieve some measure of stability in

exports.









23

A number of facets of the problem need attention and I shall endeavour

to outline some of them here. Any hope that the ivory trade will be long-

lasting depends on the future of the continent's elephant populations.

Hitherto conservation of elephant has been for their own sake. Appreciation

of the value of Ivory introduces a new aspect to their management. They

are the source of the continent's single most valuable wild life by-product.

To date Game Departments have tended to regard ivory as a sportsman's

bonus, and little more. To my knowledge there are only five African states

with any knowledge of what their total elephant stocks might be; these are

Kenya, Uganda, Senegal, South Africa and Rhodesia. The major producers'

stocks remain unassessed; these are Zaire, Tanzania, Sudan, Central

African Republic, Mozambique and Angola. However the sheer volume of

ivory coming off the continent indicates that elephant numbers must run to

several millions. This Is far more than conservationists had thought

possible. Thus In Kenya alone there were estimated to be c. 165, 000 elephants

In 1969 of which 65, 000 were in National Parks or reserves of some kind.

However it Is not numbers that should be the focal issue, but the rates of

decline. Most of Africa's elephants live outside parks. In the face of human

increase these will undergo progressive decline. There will be an inevitable

o .. .." }, ,










24

supply of ivory from this interaction of elephants and men. In addition

there will be the far greater quantities available through natural mortality.

These two inevitable sources, will constitute a basis for an ivory trade

whether it is legal or illegal for a long time to come.




The most pragmatic attitude conservationists can take is that such

declines as there may be in elephant outside parks should be kept in phase

with human Increase. This would ensure that when and if human populations

stabilise there will still be the optimal number of elephants commensurate

with that level of the human population. However there may be other

pressures and equally logical alternative policies. In a continent desperately

short of capital, bankers, industrialists or politicians may prefer to capitalise

elephants outside parks In the short term to finance development.



Another component that must be considered is the predicament of the

rural African the poacher who lives close by elephants. Generally

conservationists give little thought to the sociological consequences of their

dogmas. Subsistence peasants are under enormous pressure to join the

monetary economy. They have to have money to pay school fees, hospital










25

charges, taxes etc. Without it they cannot be part of modern society. In

much of rural Africa, particularly in drier areas, the only source of money

is wild life. It is preposterous to think that people in this situation, be they

of any race on earth, would not use ivory if they can get it. The rewards are

so great that they will take enormous risks to secure it and convert it into

money. The problem here then is how does one arrange for locals to

participate in the ivory trade legally and in an orderly manner? Certainly the

current system whereby elephants are reserved for the very rich does not

approach the problem at all.



The original legislation enacted in 1900 sought to ban free trading In

ivory in Kenya, and thereby destroy it as a medium of business. The

persistence of ivory sales over the intervening 73 years and its widespread

use today illustrate the futility of this policy. All that happens in the face of

such legislation is that the business goes underground. Today, much that is

illicit about the trade is unnecessarily Illegal and gives rise to problems

that need never exist.






(



26

For example : the Southern Sudan has precious little wealth except

ivory and the people there have no option bul to use it in trade. Their major

source of supplies for a wide range of goods is Kenya who is under

pressure to expand markets. It would be a relatively simple matter to

reach agreement at Government levels on an exchange rate for ivory and

thus bring dealing into the open where it is relatively controllable. At

present however, it is secretive, uncontrollable and both parties in trade

do not receive maximum returns. The legislation that established this

situation the banning of ivory imports into East Africa was enacted to

reduce elephant hunting In other states. It did not achieve this. For a

period the ivory went elsewhere, and today appears to be coming to Kenya

once again. This time it is illegal. A great deal of present "corruption"

in the trade would not be so if this aspect was removed. There is a need for

firm Government control, but equally a need to make legislation realistic.



The obvious way to gain stability in the ivory trade is to control prices.

Proof of this Is the long period of stability that prevailed from 1936 to 1969

In Kenya. By acting in caucus the traders appear to have maintained

considerable control in the industry. Today such control as thore is on










27

prices comes from outside Africa. It is in the interests of the continent to

try to capture such Influence. By regulating supply (as do De Beers with

diamonds) this should be possible. However a common policy between the

major African ivory producIng.states would be necessary. If four of the

larger producers were to agree on a common sales policy they could achieve

some control very quickly, but failure to act in unison would negate any

country's efforts. Thus Zaire and Tanzania which have banned Ivory

exports except through central agencies, still export quantities of ivory

through illicit channels into neighbouring states who, not having a common

policy, couldn't care less (or actively encourage It !)



Perhaps a continental ivory market could be established on the lines

of the world's metal markets in London. Kenya, with its past history as an

entrepot ivory centre, would be ideally based for such an operation.




Another aspect deserving attention is the role of Asians In the Ivory

trade. While they are to be pitied In their quandary, their continued

participation in the business during these times of uncertainty (for them)

can only lead to continued capital losses to East Africa. There is no solution









28

but to divorce them from it entirely.



Likewise the Game Department is clearly the most inappropriate

organisation to handle any aspect of ivory trading. By demonstration it

has proved inept and any re-organisation of the current situation that still

included Game Department control would create no public confidence either

locally or internationally.



I have skipped from point to point in this report and left a great deal of

ground untouched. Nevertheless I hope that it serves as an introduction to

the breadth of the ivory problem and leads to some action. In conclusion

I feel that the Kenya Government should establish a commission to review

the ivory trade. There is sufficient time and there are elephants enough

for this to be done thoroughly. Any such review should include at least

some of the Kenyans dealing In ivory. Any new legislation should seek to

establish an honourable industry in place of the furtive business that

exists at present. This would support the conservation of elephant and not

undermine it as at present.

18th October, 1973 I.S.C. PARKER





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.... -_ ---_. ---. ----_. _ . . -. '.' .. " . _.;. . =---"-:; A BACKGROUND TO \ A CONFI"OEN:\:\L REPORT MADE AT THE OF J. BLOCK ESa., OCTOBER 1973 I.S.c. Parker Wildlife Lto .. P O Box 30678 Nairobi. Kenya

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2 IVORY -A CURRENCY An article is of value if made of ivory. Ivory.is not of value certain things are made from it. In thls respect it is lika gold and the reasons why men have chosen with a very limited range of other materials, as oriteria of wealth through the ages have yet to be explained . \ Elephant tusks do not bear the seal or stamp of anyone nation, are difficult to identify as to nationality, and thus freely negotiable. With the exception of perhaps four of the smallest states in West Africa and Burundi, all oountries south of the Sahara have elephant populations and are ivory producers. It is thUG an "African" ourrenoy, and as "hard" as gold or gems. It is widely used in barter in many countries and I have personal experience of it being used to purchase vehicles, and disoussed as a means of payment for a large oemeI).t contract at Government levels. I have not had time to assemble all data available to detennine how many --------tusks leave Afrioa However it seems probable that it is in of 200,000 (100,000 elephants) and may even be as high as 400,000. The average weight of tusk exported is not yet known. It will almost oertainly

PAGE 3

3 be in excess of 4.5 kilos and could easily be 9.0 k1los. If this is the case the gross value of the continent's ivory exports will be between US $72,000, 000 and $144, 000, 000 annually. EVen if actual exports are only half the lower postUla ted figure, the volume is still "big money" in anyone's language. Ivory is durable. Though made into articles it is not "consumed". Year by year stocks accumulate and actual quantities in "circulation" must vastly exceed anyone year's production .. This acoumulated stock represents investments that run to at least hundreds of millions of dollars. With this perspective the management of the ivory trade is more the concern of international banking and government finance ministries, rather than game departments. The 1925 average value for East African ivory was Sh 37.00 per kilo Had this grown in accordance with generallnfiation at 10% annually over the intervening years, Ivory value today would be Sh 3, 663.00 a kilo. This has not happened. The actual trends in value between 1925 and 1973 are given In Table 1 and Figure 1

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4 TABLE 1 Average annual values in Shillings per kilo for East African ivory exports 1925 1973. 1925 37.65 1949 23.32 26 31.63 1950 23.90 27 30.69 51 27.80 28 29.43 52 28.13 29 26.72 53 30.51 1930 21.23 54 21.98 31 55 32.05 32 17.17 56 33.40 33 13.18 57 32 .78 34 13.18 58 31.30 35 14.09 59 29.50 36 12.37 1960 34.76 37 15.10 61 32.85 38 12.54 62 30.16 39 12.23 63 34.43 1940 13.65 64 38.67 41 12.85 65 44.29 42 15.52 66 42.26 43 20.39 67 43.36 44 20.22 68 38.84 45 21.58 69 40.14 46 25.33 1970 5G.48 47 25.66 71 67.30 48 22.22 72 68.46 1973 233.36 (US$33.S2)

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30CL.. 280-o H 220 .. I 20Q..,. L 180 .. L I 140 .. N 120 .. G S 80 60_ .,' 5 , i !f I / ............ 40.... / "--" ,.' ;----/ ................. . ----<',...-./-' \/ 20.;. '" FIG. 1 -'-. . '" '''' .. ,." . .... . .. ,,, ., ......... .. .... ,,' I "'" ". ... . 1940 1950 1960 T I M E Average East Afrioan Ivory Values 1925 1973 agalnBt a curve representing 8% annual increase. ... 1 . I 1970 1973

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6 From these it may be seen that there have been three major trends : 1) A continuous fall In value from 1925 until 1936, which coincided with the onset and durati:on of the great economio depression of tile .1930s. il) A gradual rise at approximately 4.5% annually until 1969, and ill) Very sharp rises in value 1970 -1973 averaging 75% in each year. The first of these trends seems to be the direot product of the Depression and it appears that it led to ivory being re-valued. If we take the 1936 price of Sh 12.37 per kilo as a starting point, and extrapolate a 10% growth rate from 1936 until 1973, ivory should be worth Sh 419.98 per kilo today (US $60.9'5). This price has been attained repeatedly on the international -1 vory markets this year, suggesting that growth in value has been the expeoted. However the East African Customs data for the first six months of this year indicates an average value of Sh 233.36 per kilo. If this is a genuine figure, growth over the years since 1936 has been slightly over 8% annually. I believe this to be incorrect and a reflection of illicit currency moves. ) j \

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_. --. . -. .. --.... ----, 7 The second trend in ivory values which lasted fmm 1936 untn 19G0, indicates a lower annual gain than was to be expected. I foel this i s a result of a deliberate buying policy by the major traders acting in concert, rather tllan genuinely slow appreCiation in values. For examplt3, it has never been reflected in East African values that calasia ivory (a commercial grade) was selling in India at Sh 132.00 per ldlo in 1965. Further evidence of artefact is the differences iQ, prices paid between different regions of Africa. While a certain quality may have raised Sh 33.00 peF kilo in Kenya, it would only attract Sh 16.00 in Southern Africa. However once buyers with recent East African experience bought in the south, values equalised to the East African levels. Such a situation was possible through the over-riding advantage of such a policy would have been stabilisation of production in the same manner that De Beers influence diamond sales and prices. It would also have permitted concealment of incomE) and thus fairly massive evasion of tax. Since Independence in many African States, there has also been an escalating desire by aliens to extract capital from them illegally. Depressed ivory prices provided ample cover for this. Over the period 1936 1969, the difference between the expected 10% annual

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8 appreciation of ivory value andthe actual annual rise of 4.50/0, may reflect the sum of tax evasion and concealed currency movements that have taken place. If this is so, the amount is considel"able The third trend apparent in the data in Table 1 and Figure 1 represents a rapid rise from the depressed prices that prevailed until 1969 to the real values that are the product of 10% annual inflation since 19313. These rises have coincided with growing monetary 'instability and major declines in the value of the US Dollar. Widespread uncertainty in "national currencies" led to an urge to invest in "international currenoies" -ivory and gold etc. This drive has been particularly strong in the East. Normal channels were unable to meet demand and speculators started widespread buying at source -in Africa. Even at Government levels there has been support for tills approach. An example : The Japanese Government has stocks of US Dollars that threaten to devalue considerably and therefore wished to "dump" them. African countries need "hard" currency, no matter how "de-valued" it may be, and are therefore prime "dumping" grounds. Most have, in addition, substantial trade imbalances with Japan. Rather than pay the real value to the middlemen in

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....... .... ... ... -....... ...... --_._--_ -.-. _... 9 Hong Kong, it pays the Japanese to give the full rate to Africa to gain substantial balance of trade benefit. Japanese, with Government blessing, thus exchange their dollars for ivory (to everyone's delight except the I traditional traders). Similarly, s'1bstantial quantities of ivory have made their way to Peking, particularly from Tanzania. The situation has been given greater complexity by the desire of many aliens in Africa to extract investment from the continent, or to invest outside it. This urge has reached a measure of desperation with Asians in Kenya, but it also includes many prominent Africans in a number of states. A measure of what may have been kept overseas from exports in the first 6 months of 1973 may be revealed by Customs Department valuation of these at approximately US $35.00 per kilo. In this period much ivory haa in fact obtained over $60.00 per kilo. On the basis of my personal experience I think that the average price for all grades must have been $45.00 over the 6 months, giving a margin of $10.00 over the Customs value. If this is the case proceeds kept outside Kenya will have amounted to $2, 136, 730 or S 824, 992.27. l j I I 1 I I I i

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10 In conclusion: ivory is currently near its "real" values in Africa. However speculation in it is wild and erratic. As I write I am aware of a major London firm trying to sell a consignment of ivory, currently in Beirut, ex Khartoum, worth many thousands of dollars, to a company in Botswana for resale to the Far East no one in the London firm having seen the consignment or dealt in ivory before. The sitUation has many of i the ohaotio aspects of a gold rush, and it is in Africa's interests to \ i organise the trade.

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./ 11 KENYA'S IVORY TRADE I The most fundamental and continuous influence on elephant numbers throughout this century has been human expansion. As people increase ( they take up more land displacing elephant that may live on it. This process is unnvoidable and would continue irrespective of any demand for ivory. Kenya's domestio ivory exports over the period 1925 1973 reflect this procefls of attrition. The relevant data are presented in Table 2 and Figure 2. From these it may be seen that the ex ports oscillated around a growth rate of about 3% annually until 1970. The two major depressions in the export pattern coincide with the second world war and Mau Mau emergency respectively. Logically, it appears 'that these two political events temporarily slowed output of ivory. Abrupt increases commenced in 1971. In that year exports rose by 86% over the preceding year. In 1972 there was a further increase of 81 % over 1971, and the first six months of 1973 saw a further gain of 42% over the whole of 1972's putput.

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------_ _._--_ _-----'-"-' 12 TABLE 2 Kenya's annual exports of Domestic ivory in kilograms 1925 1973. I 1925 16,303 1949 23, 116 26 14,915 1950 25,606 27 25,575 51 22, 507 28 14,899 52 14,784 29 12,224 53 16,918 1930 16,275 54 15,741 31 13,280 55 33, 159 32 13,941 56 31,889 33 18,998 57 23, 905 34 21,162 58 26,310 35 19,506 59 27,262 36 18,145 1960 29,261 37 15,877 61 32,615 38 13,307 62 40,826 39 12, 396 63 42, 096 1940 11,126 64 39,120 41 12, 542 65 29,311 42 5,639 66 45,213 43 5,839 67 48,350 44 13,209 68 38,572 45 14,733 69 33,388 46 34,751 1970 44,383 47 71 82,727 48 19,712 72 150, 305 1973 213, 673 (6 months only) . . .

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220 ... 200... 1 180':' 0 o S o F i K lOQl.. I 901 L 80 i "! o f 70 : G f R A M 40 S f -----. ----. -.----------. -.-. --. 13 FIG. 2 Kenya's Annual Exports in Kilograms 1925 -1973 I { 3% growth ourve Annual Exports \ \ ' \, \ \. I I I I I ..' -, .... .. ....... .... : .......... ....... ..... ............... ..... .. I .... .... ... .... .... ......... ... ... ..... ............ ........... ........ . .. ... .... .... .. ........ ..... ... .. 1925 1930 1940 1950 1960 1970 1973 TIM E

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14 Examination of export response to inoreases in value is made for the period 1925 1973. FIgure 3 Illustrates the relationship graphically. It seems fairly clear that price increases coincide with increases in exports. The great growth of exports 1'971 1973 seems a direct response to the rocketing local values. Otl1er than the general export statistics kept by the Customs Department, there is no composite collection of data relating to the trade in Kenya. Theoretically, the Game Department should be able to trace the origin of every tusk legally possessed In Kenya. This is not the case. Apparently most of the Department,'s records prior to 1965 have disappeared and no aIinual reports have been issued since 1965. Even the number of animals shot on control by the Department itself seems subject to dispute. Nevertheless, despite the absence of accurate data, it Is possible to assemble a speculative picture of what has been happening. Let us concentrate on domestic ivory exports for the first six months of 1973. In this period 213.67 tons were recorded as leaving Kenya. To have been documented by Customs all this ivory must have been covered by

PAGE 15

, i \ . 1925 \ FIGURE 3 + .. Changes in values from year to year related to changes In eXp:Jrt volumes 1925 1973. 1925 196Z Total E. A. ivory trade volume '. r I I 1962 1973 Domestic exports only as imports ceased in 1962 , / I I I I I I 1 "!: Export volume -.--... ---.---.. ::. Value l i \ \ \ \ \ \ \ \ \ 1930 -.. /'-\ .... : / l\ I . ', ,I J i -'./ I I I I I I I I j .... ""... t ....... 1940 # .......... \ I I \ I I I I / J .' / I ;.,-I I ... .... ..... ........... . ... 1950 ,. r I .. J \ \ I / ./'/-'-.. \. J I \ I \ \ \. : \ -I ,! 1 I I \; I I I I t I I I \ I 1 I I I I I I I .... ...... ... ... ... ....... .............. . 1960 / I I J I ) 1\ '." r '..,/ \ I \ I! \ ,'I' i \ '\ I I ; \}\ ; j : . / I I I ! t .. I 10701)7 I i I i i I I I I

PAGE 16

----_ .. . ._ . . _ _ . _--/ 16 pennits from the Game Department. Legal sources of ivory are limited to : i) Elephant shot on licence. It would appear from data obtained from the Department that t,qis source accounted for c.:n tons (14.5% of total exports). li) Game Department control shooting. It is difficult to get figures on this. Normally the .Mombasa auctions provide some. information on the amount of control work, but in 1973 such ivory appears to have been disposed of by other means. At the only auction held this year the Department produced only 0.68 of a ton (0.3% of exports) :174 tusks averaging 3.9 kilos each (this must be the smallest quantity auctioned by the Game Department in Mombasa in 60 years). It is believed that about 500 elephant were shot on control In 1970 and that the numbers have not substantially increased sInce then. If this is so the six months of .our interest should account for 250 elephant. Should these provide 27.22 kilos of ivory each (a generous figure in view of previous records) control should have provided 6.8 tons (3.18% of the 6 months' exports) Hi) Natural Mortality. This normally provides a substantial quantity of ivory for Government. Its absence at the last auction is puzzllnz.

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i __ 0 ______ ._.--'" ----_. .. -. _ .... ---.. 17 It is also the major source of national parks' ivory and part of the ivory gathered from the 1971 die-off of elephants in Tsnvo was sold in June. This amounted to 16.9 tons (7.9% of the 6 months' total). . iv) Collectors' Permits. These permits are an innovation that appeared in the late 1960s. Essentially they are a Chief Game Warden's Permit (given by that officer at his disoretion) allowing an individual (or group) to "collect" ivory. Presumably the rationale is to permit the recovery of "found" ivory (a very good reason as natural mortality --------constitutes the largest potential source of ivory in the country.) --------... ---------' '-----However, it would appear that these collectors' permits are responsible for 163129 tons (76.4% of the 6 months' exports) out of the 213.67 tons exported. This may be so, but there is no precedent to suggest that this could have come from "found" ivory. It would be naive to conclude anything other than the collectors' permits have been used as an extensive cover for illegal ivory trading. Let us now consider illegal aspects of the trade. There are two major sources of illicit ivory: internal poaching and the import of ivory from ------------_ .. --_ ... ------_._-------outside Kenya. In concord with rising price of ivory, there has been a

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______ ---...L. ... . ___ _ ____ -18 growing outcry over the amount of elephant poaching taking place in 1973. In the main reports of this stem from professional hunters and to a lesser degree from national park wardens. There has been considerable subjective I corroboration of these through the abundance of elephant carcasses Sighted from the air. There can be no do!lbt therefore that elephant poaching in Kenya has reached high levels even though it is not possible to place reliable figures on its extent. What is of considerable importance in this analysis is that though 1971 and 1972 experienced massive increases in ivory exports, there were no comparable outcries about poaching to that in 1973. This raises the possibility that at least part of the recent exports came from outside Kenya. For Kenya to deal in this commodity would be nothing new. Prior to 1962, Kenya's total ivory exports were comprised of 3 to 4 times as much lmported ivory as there was domestic production. Mombasa was the biggest entrepot ivory centre on the continent outside Zanzibar. From my trading outside East Africa, I am aware that considerable "quantities of ivory are "indeed being Bent to Kenya. I was personally t

PAGE 19

19 approached by two African ivory dealers in Nairobi, both of whom wanted to buy ivory from outside Kenya. Both scoffed at the idea that there should be difficulty in getting any amounts into the country "legally". A Zairean gentleman offered me a supplS of 5 tons a week in NairobI (ex Zairo). Similar quantities to this pass through Juba from Zaire weekly, and I haveno grounds to disbelieve the offer At least one Nairobi company has handled substantial quantities of Tanzania ivory this year. Tanzanian hunters openly admIt they send their ivory to Nairobi. Examination of Tanzanian statistics indicates that last year 250 tons were exported, but that unlike Kenya, the values declined from the 1971 level by 20%. (Evidence of a state monopoly lowering prices out of phase with general trends and thereby creating incentive to by-pass it illegally.) This year Tanzanian exports are down very steeply indeed, and though the price is up on 1972, it Is still well below Kenya's level It is certain that quantities of Tanzania ivory are coming to Kenya illegally to take advantage of higher prices -hence the decline in this year's legal exports from that country. All my evidence indicates that considerable quantities of ivory are coming into Kenya from neighbouring and nearby states. } J I \

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_ _______ 0 ___ ____ _ _____ ____ 20 Finally, to oonclude this chapter, I must make some comment on who is in the trade. At the moment Asians are still the largest dealers in ivory. One Na1robi family alone has accumulated more than 100 tons of ivory in Hong Kong. Most of them have "shadow" companies in Europe or the Far East who act as their "buyers". For them it is a major route for getting substlilltial quantities of capital away from Africa. There are a few Europeans trying to enter the trade for the same reasons as the Asians, but these, fOT the most part, have been singularly unsuccessful ma1nly through complete ignoranoe of how to set about it! However, there is a very rapidly growing African involvement in the trade, as has been apparent from the pr..st two auctions in Mombasa. Some have "gone it alone". Others have entered into partnerships with Asians. The outstanding point is that some of these Africans are of political consequence. The liaisons they make -both internationally and internally -may have repercussions beyond the sphere of business, especially If any illegality is involved. Blackma11 becomes a probability. i -; l I \ \

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--_.. _ . .__ 21 THOUGHTS ON FUTURE POLICY I shall summarise the ground covered so far: 1. Ivory is a currency of international standing that is presently in great I demand. Its to Africa runs to millions of dollars annually, as well as serving to facilitate inter-state trade. However, the cumulative quantities outside Africa -particularly the Far East l'epresent investments that must run to at least many hundreds of millions of dollars. 2. There is no effective management of the resource in Africa. By demonstration, conservation departments are in ignorance of the and totally unequipped to handle it. Such control as there has been appears to have been effected by the ivory traders themselves influencing production through prices. Tenuous at the bes t, thls has been destroyed by instability in the world monetary system and trends in African politics. Currently elephant management and the ivory trade Is a scene of chaos and wild speculation. 3. Kenya's exports have soared in response to rising local prices. They have been used as a major vehicle for transferring capital out of the country. Funds lost to Kenya in the first six months of 1973 may have been of the order of US $2, 136, 730.00.

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-..:..... . .... --.. -_ . _ .. _ ... . _. 22 4. Kenya's exports of 213.67 tons of ivory in the first six months of 1973 cannot be satisfactorily accounted for by conventional legal sources. It would appear that the "unconventional" collectors' permits may be. I . responsible for 76% of expo.rts -and are felt to have given cover to much illegal ivory. 5. The level of poaching in Kenya is currently high, but probably does not account for the bulk of illegal ivory. This is made up from sources outside Kenya. 6. There are people of great political consequence in Kenya involved in the ivory trade. In view of the enormous sums of money represented by ivory, suoh involvement could have much wider repercussions than Initially apparent. There is an obvious case for the organisation and management of Africa's Ivory trade. However the subject is so wide and with such far-reaching implioations that at this stage all one could hope to do would be to obtain more information and perhaps try to achieve some measure of stability in exports,

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. --_._-_._-_ . _._ .. ___ .. _____ H 21 THOUGHTS ON FUTURE POLICY I shall summarise the ground covered so far: L Ivory is a currency of lnternational standing that is presently in great demand. Its value to Afric.a runs to millions of dollars annually, as well as serving to facilitate inter-state trade. However, the cW11ulative quantities outside Africa particularly the Far East represent investments that must run to at least many hundreds of millions of dollars 2. There is no effective management of the rosource in Africa. By demonstration, conservation departments are in Ignorance of the situation and totally unequipped to handle it. Such control as there has been appears to have been effected by the ivory traders themselves influencing production through prices. Tenuous at the best, this has been destroyed by instability in the world monetary system and trends in African politics. Currently elephant management and the ivory trade is a scene of chaos and wild speculation. 3. Kenya's exports have soared in response to rising local prices. They have been used as a major vehicle for transferring capital out of the country., Funds lost to Kenya in the first six months of 1973 may have been of the order of US $2, 136, 730.00.

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-------_ .... .... .... . . . ---_ . . --_. 22 4. Kenya's exports of 213.67 tons of ivory in the first six months of 1973 cannot be satisfactorily accounted for by conventional legal sources. It would appaar that the collectors' penuits may be I I reaponsible for 76% of expo.rts -and are felt to have given cover to much illegal ivory. 5. The level of poaching in Kenya is currently high, but probably does not account for the bulk of illegal ivory. This is made up from sources outside Kenya. 6. There are people of great political consequence in Kenya involved in the ivory trade. In view of the enonnous sums of money represented by ivory, such involvement could have much wider repercussions than InItlally apparent. There is an obvious case for the organisation and management of Africa's ivory trade. However the subject Is so wide and with such far-reaching implications that at this stage all one could hoIXl to do would be to obtain more information and perhaps try to achieve Bome measure of stability in exports.

PAGE 25

23 A number of facets of the problem need attention and I shall endeavour to outline some of them here. Any hope that the ivory trade will be long-lasting depends on the future of the continent's elephant populations. Hitherto conservation of eleph8}it has been for their own sake. Appreciation of the value of ivory introduces a new aspect to their management. They are the source of the continent's single most valuable wild life by-product. To date Game Departments have tended to regard ivory as a sportsman's bonus, and little more. To my knowledge there are only five African states with any knowledge of what their total elephant stocks might be; these are Kenya, Uganda, Senegal, South Africa and Rhodesia. The major producers' stocks remain unassessed; these are Zaire, Tanzania, Sudan, Central African Republic, Mozambique and Angola. However the sheer volume of ivory coming off the continent indicates that elephant numbers must run to several millions. This is far more than conservationists had thought possible. Thus in Kenya alone there were estimated to be c.165, 000 elephants In 1969 -of whioh 65,000 were in National Parks or reserves of some kind. However it Is not numbers that should be the focal issue, but the rates of deoline. Most of Africa's elephants live outside parks. In the face of human increase these will undergo progressive decline. There will be an inevitahle "",": .. ',. \ \ \ i 1 i

PAGE 26

24 supply of ivory fro;m this interaction of elephants and men. In addition there will be the far greater quantities available through natural mOltality. These two inevitable sources, will constitute a basis for an ivory trade whether it is legal or illegal for a long time to come. The most pragmatic attitude conservationists can take is that such declines as there may be in elephant outside parks should be kept in phase with human increase. This would ensure that when and if human populations stabilise there will still be the optimal number of elephants commensurate with that level of the human population. However there may be other pressures and equally logical alternative policies. In a continent desperately short of oapital, bankers, industrialists or politicians may prefer to capitalise elephants outside parks in the short term to finance development. Another component that must be considered is the predicament of the rural African -the poacher who lives close by elephants. Generally conservationists give little thought to the sociological consequences of their dogmas. Subsistence peasants are under enormous pressure to join the monetary eoonomy. They have to have money to pay school fees, hospital

PAGE 27

.. _ ._._-------25 charges, taxes etc. Without it they cannot be part of modern society. In much of rural Africa, particularly in drier areas, the only source of money is wild life. It is preposterous to think that people in this situation, be they of any race on earth, would not use ivory if they can get it. The rewards are so grent that they will take enormous risks to secure it and convert it into money. The problem here then is how does one arrange for locals to participate iIi the ivory trade legally and in an orderly manner? Certainly the current system whereby elephants are reserved for the very rich does not approach the problem at all. The original legislation enacted in 1900 sought to ban free trading in ivory in Kenya., and thereby destroy it as a medium of business. The persistence of ivory sales over the intervening 73 years and its widespread use today illustrate the futility of this policy. All that happens in the face of such legislation is that the business goes underground. Today, much that is illicit about the trade is. unnecessarily illegal and gives rise topl'Oblems that need never exist.

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26 For example: the Southern Sudan has precious little wealth except ivory and the people there have no option bu' to use it in trade. Their major source qf supplies for a range of goods is Kenya who is under pressure to expand markets. It would be a relatively simple matter to reach agreement at Government levels on an exchange rate for ivory and thus bring dealing into the open where it is relatively controllable. At present however, it is secretive, uncontrollable and both parties in trade do not receive maximum returns. The legislation that established this situation -the banning of ivory imports into East Africa was enacted to reduce elephant hunting in other states. It did not achieve this. For a period the ivory went elsewhere, and today appears to be coming to Kenya once again. This time it is illegal. A great deal of present "corruption" in the trade would not be so if this aspect was removed. There is a need for firm Government control, but equally a need to make legislation realistic. The obvious way to gain stability in the ivory trade is to control prIces. Proof of this Is the long period of stability that prevailed from 1936 to 1969 In Kenya. By acting in oaucus the traders appear to have maintained considerable control in the industry. Today suoh control as thore is on

PAGE 29

i ----. .--. ,. 27 prices comes from outside Africa. It is in the interests of the continent to try to capture such influence. By regulating supply (as do De Beers with diamonds) this should be possible. However a common policy between the major African ivory produCing-states would be necessary. If four of the larger producers were to agree on a common sales policy they could achieve some control very quickly, but fallure to act in unison would negate any . country's efforts. Thus Zaire and Tanzania which have banned ivory exports except through central agencies, still export quantities of ivory through illicit channels into neighbouring states who, not having a common policy, couldn't care less (or actively enoourage it !) Perhaps a continental ivory market could be established -on the lines of the world's metal markets in London. Kenya, with its past history as an entrepot ivory centre, would be ideally based for such an operation. Another aspect deserving attention is the role of Asians in the ivory trade. While they are to be pitied in their quandary, their continued participation in the business during these times of uncertainty (for them) can only lead to continued capital losses to Eaat Africa. There is no solution

PAGE 30

i .... . ... -.. ...... . ---. "'--" ". 28 but to divorce them from it entirely. Likewise the Game Department is clearly the most inappropriate organisation to handle any aspec;t of ivory trading. By demonstration it -_. .. .. ..... has proved inept and any re-organisation of the current situation that still included Game Department control would create no public confidence either locally or internationally. I have skipped from point to point in this l"eport and left a great deal of ground untouched. Nevertheless I hope that it serves as an introduction to the breadth of the ivory problem and leads to some action. In conclusion I feel that the Kenya Government should establish a commission to review the ivory trade. There Is sufficient time and there are elephants enough for thIs to be done thoroughly. Any such review should include at least some of the Kenyans dealing In ivory. Any new legislation should seek to establish an honourable industry in place of the furtive business that exists at present. This would support the conservation of elephant and not undermine it as at present. 18th October, 1973 1. S. C. PARKER