Examining the Influence of Corruption on the Practice of Trophy Hunting in South Africa

Abstract

This study examines the perceived influence of corruption on the practice of trophy hunting in South Africa, the largest trophy exporter in Africa. Corruption is a major problem in South Africa, where it takes the form of bribery and embezzlement. To investigate its perceived effects on the practice of trophy hunting, semi-structured interviews were conducted with 15 trophy hunting stakeholders in South Africa. Interviews were conducted via Zoom, recorded, transcribed, and coded using a qualitative content analysis. Six of the 15 respondents had personally witnessed corruption in the trophy hunting industry in South Africa, and 13 respondents had heard accounts of corruption witnessed or experienced by others. Respondents identified several perceived problems caused by corruption in the trophy hunting industry and suggested ways to mitigate corruption. Based on these results, a multi-pronged approach for addressing corruption within the trophy hunting industry in South Africa may be necessary.

1. Introduction

1.1. Trophy Hunting and Corruption Concerns in South Africa

Trophy hunting (TH) is defined as “an activity where wildlife is hunted by means of a rifle, bow or similar weapon primarily for their horns…skin [or other body parts], in order to be displayed as trophies” [1]. TH is a divisive topic; some argue that, when well-managed, it offers conservation benefits to target species, conservation incentives for areas of land used for hunting, and socioeconomic benefits to local communities that live in or near hunting areas [2,3,4,5,6,7]. Others contend that TH is linked to negative conservation impacts [6,8,9,10,11,12], unethical hunting practices [4,5,6,13], adverse evolutionary effects [14,15,16,17,18], and socioeconomic problems for local communities that are intended beneficiaries of the TH programs [5,7,19,20,21].

South Africa supports the largest TH industry in Africa in terms of numbers of operators, visiting hunters, animals shot, and revenues generated [22]. South Africa allows the legal hunting of vulnerable, threatened, and endangered species if research suggests that hunting pressure will not harm these populations. For example, the South African Department of Forestry, Fisheries, and the Environment specifies annual quotas for the hunting of African elephants (Loxodonta africana), leopards (Panthera pardus), and black rhinoceroses (Diceros bicornis), which are listed on the International Union for the Conservation of Nature Red List of Threatened Species [23,24,25]. In 2022, these quotas were set at 10 leopards, 10 black rhino, and 150 elephants. Quotas are determined at the end of each hunting season, using what the government considers the “best available scientific information” on the conservation status of each animal [26]. These quotas are consistent with guidelines established in the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), which currently allows the annual legal export from South Africa of 150 elephants, 150 leopards, and 0.5% of the black rhino population. Trophy hunters must obtain permits, which can also be used to specify how many animals of any species can be taken, in which areas, and at what times.

The South African government regards TH as a critical sector that is “part of the South African heritage and culture… [and] generates economic benefits as part of the South African rural economy” [26]. Fees generated from the trophy hunting of endangered or threatened species totaled an estimated ZAR 208 million (about USD 11 million) in 2019, with the overall hunting sector contributing ZAR 1.4 billion (USD 73.8 million) to the national economy that year. A 2018 study of the broader economic impact of trophy hunting in South Africa [27] estimated that the industry contributes USD 341 million to the national economy and supports 17,000 jobs. Although estimates of the economic impact of TH vary, this practice is clearly a significant component of South Africa’s tourism industry.

Although the government has policies in place to regulate the TH industry, the economic and conservation benefits of TH could be undermined by corruption, especially given the significant financial returns generated by the industry. Corruption is defined as “the unlawful use of public office for private gain” [28]. Corruption takes many forms, including embezzlement, accepting bribes to overlook illegal activities, and demanding bribes to certify compliance [29]. It is considered widespread in Africa [30,31,32] and is pervasive in South Africa [33,34,35,36], including among enforcement authorities [37]. Anti-corruption agencies within South Africa are considered largely ineffective [35]. Corruption is also seen as a major challenge to good governance in South Africa [36]. Wildlife conservation is negatively impacted by corruption, as it diverts financial resources meant for conservation, hampers law enforcement efforts, and derails forms of political support that are critical to conservation efforts [38,39,40,41,42]. Corruption is often most rampant in countries where salaries for government officials are low, there is little or no accountability, regulatory systems are weak, and political systems afford corrupt practices [32]. These same countries—South Africa included—are also often home to high levels of biodiversity and species that are highly sought-after by trophy hunters; corruption may undermine the potential conservation benefits associated with TH and place target species at risk [39,40,41,42,43].

To date, there have been very few systematic studies examining the possible influence of corruption on TH, and these have limited geographic scope. South Africa has not been the focus of past research, despite having the largest TH industry in Africa. The few studies that do exist suggest that corruption may be a serious issue. Leader-Williams, Baldus, and Smith [44] used web-based research to identify concerns and allegations of corruption in the recreational hunting industry with a special focus on Tanzania. They identified possible problems with the allocation of hunting licenses and permits, misappropriation of fees, infringements on regulations (e.g., using bait to lure animals), bribery, and mishandling of quotas. They concluded that additional research is needed to understand the incidence of corruption in different locales, the possible effects on target populations, and avenues for reform. Smith et al. [43] found that governance scores better explained changes in the populations of black rhino and African elephants than any other variable considered; they urged conservationists to focus on developing policies to address corruption, particularly in areas with high biodiversity and low governance scores. Smith and Walpole [41] argue that conservationists must pay more attention to corruption because of its potential to reduce program effectiveness and incentivize overexploitation.

One recent study that did focus on South Africa compared the hunting data available in the South African Professional Hunting Statistics (SAPHs) database with the export data available in the CITES trade database. The authors found considerable discrepancies between the number of animals reported killed (4726) and the number of trophy items exported (3131) in 2018 [45]. They recommended that South Africa improve strategies for managing the wildlife trade, especially documentation procedures. The success of TH as a conservation strategy depends in part on the collection of accurate data on the number of animals killed and exported; this allows officials to assess whether animals are being hunted at a sustainable rate and whether quotas are being exceeded. Additional research is needed to understand whether these discrepancies are the result of inadequate recordkeeping practices or actions that would constitute corruption.

Many of the species targeted by the TH industry and the hunting areas themselves are of high conservation value [40,41], and understanding the scale and ripple effects of potential corruption within the industry is vital [39]. Since the political systems and programs under which TH operates in African countries are regularly in flux [46,47], continued research into the influence of corruption on TH is needed. If present, corruption could potentially undermine the intended benefits of TH by making it difficult to assess how hunting impacts species populations and diverting socioeconomic returns from the intended communities. This study builds on prior research by focusing specifically on the possible links between corruption and TH in South Africa and directly investigating local perceptions of these connections. The results help frame specific types of corruption in a structural context—pinpointing the specific aspects of the TH system in South Africa that are most vulnerable to corruption—and provide valuable suggestions from local stakeholders about how these problems could be addressed.

1.2. Scope of the Present Study

This study examines perceptions of corruption related to the TH industry in South Africa, whether witnessed first-hand or heard second-hand, to help understand how pervasive corruption may be, how it impacts TH, and how it could be mitigated. These findings may inform law enforcement strategies used to combat corruption, help ensure local communities benefit from wildlife, and inform TH regulations and trade policies for trophies, both in South Africa and in countries where trophy-hunted species from South Africa are imported. These results may also help officials more effectively conserve the wild animal species targeted by trophy hunters, especially species considered vulnerable to extinction or listed as endangered or critically endangered.

In a recent letter published in Biodiversity in Conservation, Darragh Hare and others argue that “continuing to discuss trophy hunting as if it is a single activity will perpetuate long-standing, polarizing debates without helping to resolve them” [48]. They maintain that trophy hunting practices vary widely, and a fine-grained analysis is needed to understand whether TH is ecologically and/or economically effective in different contexts. This article does not adopt a stance on whether TH is universally good or bad, but instead attempts to shed light on how specific types of corruption may be impacting TH outcomes in South Africa, how local stakeholders view the impacts of potential corruption on the industry, and what actions they think could be carried out to mitigate possible impacts.

1.3. Previous Research on Local Perceptions of Trophy Hunting

In asking these questions, this article also contributes to the recent literature examining local perceptions of TH. Much of the debate surrounding TH centers on Western perceptions of the practice, which have been profoundly shaped by news coverage of events like the 2015 killing of Cecil the Lion in Zimbabwe (e.g., [49]), and local perceptions are often notably absent from this debate. Local perceptions of TH are critical for strengthening governance strategies and assessing the degree to which TH is ecologically and economically sustainable in specific places.

There is a notable lack of research on local perceptions of TH in South Africa specifically. However, research conducted elsewhere provides insight into why local perceptions are valuable for understanding the benefits and drawbacks of the TH and possible avenues for reform. A recent study of local perspectives on TH in Namibia’s Bwbwata National Park [50] found that, while community members experienced some forms of social, economic, and environmental empowerment stemming from their participation in the industry, they also noted that returns from TH were inequitably distributed (e.g., due to corruption and nepotism), and they expressed a lack of trust in hunting operators and the Kyaramacan Association, the group that legally represents all people living in the park. The authors stressed that “TH can only be sustainable when community participation and empowerment are integrated into policy and development strategies” (p. 223). Understanding inequities and corruption in the TH system is critical for enhancing community empowerment and fulfilling the economic and social goals of TH.

In a comprehensive study of local opinions on TH in Kyrgyzstan, Nordbø et al. [51] assessed how local inhabitants view the positive and negative impacts of the practice in At-Bashy, a region home to two endangered species, argali (Ovis ammon) and ibex (Capra sibirica). They found that about 70% of participants did not support the further development of the TH tourism industry locally because most did not feel that they benefited from the revenues; the general perception was that “people in positions of influence are seen to make a lot of money from trophy hunting while the local population in the destination area continues to suffer from poverty” (p. 80). Examining local perspectives helped delineate the stark differences between government narratives regarding the industry’s success and local experiences of how TH is governed and how returns are distributed. The authors stressed the need for more stringent regulations and more transparent decision-making processes within the TH industry in Kyrgyzstan.

Mkono [52] examines Africans’ views on trophy hunting in social media, specifically comments made by Africans on the Facebook pages of three major news outlets (BBC New Africa, News24.com, and News-Day Zimbabwe) in response to stories about TH. Mkono writes that, for these African commenters, “trophy hunting was not objectionable from an animal rights perspective, but [rather] as a consequence of its complex historical and postcolonial associations” (p. 689). They shared the opinion that Westerners tend to view animals as more valuable than humans, and they associated TH with a long legacy of African resources being exploited for elite foreign gain at the expense of local communities. Citing Garland [53], Mkono notes that some “Western wildlife scientists and advocates working in Africa, although not all, are often ignorant of local worldviews, and frequently lament locals being corrupt, ‘in it for the money’, or lacking the skills required to carry out conservation work” (pp. 689–690). Advocates describe TH as a way of creating an environmental ethic among local people who lack the ability or desire to conserve these species and their habitats. African commenters disputed this characterization of local communities, but they also decried what they saw as widespread corruption among officials. They viewed TH as “the product of complicity between white men and greedy African leaders … [P]osters felt that only the political elites and their families were enjoying the economic proceeds from the trophy hunting industry” (p. 699).

Given the widespread public perception among both “Westerners” and Africans that corruption may be undermining any good that can come from TH, research on local perceptions of this problem (and what to do about it) is needed.

2. Materials and Methods

To inform the selection of stakeholders to serve as interview subjects, a systematic review of the literature on the influence of corruption on TH was conducted using key words such as “trophy hunting”, and the synonymous term “sport hunting”, along with the Boolean operator “and” with the terms “corruption”, “bribe”, and “nepotism” to find literature relevant to the research topic. The resulting articles, both peer-reviewed and not, were rapidly evaluated to ensure they were of relevance to the topic of corruption in the global TH industry, with an emphasis on Africa. The lead author (Peyman) analyzed this literature, systematically noting the forms of corruption described, the perceived influence that corruption had on the practice of TH, the effects of the corrupt practices on the potential benefits of TH, and any other threats or risks introduced by perceived corruption within the industry.

The results of this literature review informed the development of a semi-structured interview guide to assess how stakeholders involved in TH in South Africa perceive the potential impacts of corruption on the industry. The interview guide contained ten main questions, each of which was associated with follow-up questions that depended on respondents’ answers. The research plan was reviewed and approved by the Institutional Review Board of the University of Illinois Springfield. Although the lead author (Peyman) worked full-time for Humane Society International (which has adopted a policy stance critical of TH) at the time of this study, this research was conducted as part of a research project for a master’s degree in environmental science at the University of Illinois Springfield. The lead researcher made every attempt to avoid bias by interviewing stakeholders involved in all aspects of TH, including those who are supportive of the practice, those who are critical of it, and those who are charged with regulating or overseeing TH in South Africa. The perceptions of all these stakeholders are examined in Section 3.

Contact information for potential participants was gathered with the assistance of two contacts at Humane Society International/Africa, and additional respondents were identified via snowball sampling. Each participant was asked if they would be willing to recommend other individuals with perspectives relevant to this study. Each potential participant was contacted via email and sent a document that sought their oral consent to participate in this research study. This document disclosed the fact that the lead researcher was affiliated with Humane Society International. The document also explained the purpose of this study, potential risks to the participants (potential discomfort discussing corruption and related activities), the potential benefits of this study, and the logistics of the interview process, including the use of Zoom and the audio recording of each interview. Prior to each interview, the interviewer confirmed that each participant had read the oral consent to participate in the research study document, went through the key points to ensure that the participants were all 18 years of age or older, understood their rights as participants, were participating voluntarily, agreed to have the interview recorded, and gave oral consent to participate and commence the interview.

Using the questionnaire, semi-structured interviews were conducted with 15 participants to examine their perceptions of corruption in the TH industry in South Africa in March and April 2021. Each interview lasted about an hour, but the interviewer did not restrict the interviewees if they wished to speak longer or elaborate on any question or topic. Unfortunately, the principal researcher’s affiliation with Humane Society International—a non-governmental organization with active campaigns opposing the practice of TH in South Africa—was identified as a reason for hesitancy on the part of participants, and some who participated in this research study said that other potential respondents refused to participate because of this affiliation. This was a major limitation of the recruitment process. There are also inherent challenges in researching corruption, since study participants may be hesitant to share information that could implicate themselves or others in illegal activities. Other qualitative studies on related illegal practices have seen similarly low levels of response (see, for example [54]). Despite the small sample size of 15 participants, their perceptions (presented below) are valuable for identifying how corruption may impact TH in South Africa, and how these influences could be mitigated. Further research can explore the relative pervasiveness of these issues in more depth.

The audio recording files of the Zoom interviews were stored on a personal computer and backed up on the UIS Box system using AES-256 encryption. Only the lead author has access to these files. The recordings were labeled with only participant numbers and no names or personal identifiers were associated with the files or stored in the same files. The key that linked the respondents’ numbers with their names was password protected and stored using the aforementioned encryption. Each of the transcriptions were analyzed and coded to create thematic and categorical groupings [55] to identify key phrases, common experiences, and perceptions to enable a quantitative analysis of how respondents perceive or have experienced corruption and its influence on the practice of TH in South Africa. In the following sections, accounts provided in the interviews are included verbatim or paraphrased for brevity and clarity to ensure the retention of the original meaning and intention of the participants.

3. Results

The participants represented a wide variety of stakeholder groups related to the TH industry in South Africa (see

Table 1. How are respondents involved in the TH industry in South Africa?

Respondent Category	Count	Percentage of Total
Provincial wildlife authority	5	33.33
South African conservation/wildlife protection NGO	3	20.00
Professional hunting association	2	13.33
Research consultant/environmental journalist	1	6.67
Researcher/economist	1	6.67
National park/nature reserve employee	1	6.67
Wildlife rancher/wildlife specialist	1	6.67
Member of the judiciary	1	6.67
Total	15	100.00

below). A total of 15 respondents participated in this study, which included 13 men and two women. These stakeholder groups were carefully chosen to sample across the many people who play important roles in TH and conservation initiatives in South Africa. In public forums, sport hunting associations tend to be supportive of TH in general; conservation NGOs tend to be critical of the practice. As discussed previously, the South African government views TH as an important tool for achieving economic development and conservation goals. Regardless of their professional affiliations, all study participants were in positions that might allow them to observe instances of corruption within the TH system (if present). Respondents were asked to report their personal opinions and observations, but their structural roles within the system and their professional affiliations likely influenced their responses and their interpretations of the significance of corruption in TH.

The first question asked whether the respondent thinks TH is effective as part of a big game conservation strategy in South Africa. A total of 40% of respondents either agreed or strongly agreed that TH is effective. A total of 27% agreed but had concerns, principally that the TH industry must be managed well to ensure it is effective (e.g., not marred by corrupt and unethical practices) and benefits local communities as intended. A total of 33% of respondents strongly disagreed with the statement, indicating that they think TH is an ineffective conservation strategy.

Not surprisingly, responses to this question varied somewhat in conjunction with the respondents’ roles within conservation and TH. Both representatives of professional hunting associations and two provincial wildlife authority officers responded that they strongly agreed that TH is effective as a conservation strategy. One provincial wildlife authority officer and one wildlife rancher/wildlife specialist responded that they agree that that TH is effective as a conservation strategy, while two provincial wildlife authority officers, one member of the judiciary and one representative of a South African conservation/wildlife protection NGO, responded that they agreed that TH is effective as a conservation strategy, but they had concerns about the practice. Two researchers, two representatives of South African conservation/wildlife protection NGOs, and one national park/nature reserve employee strongly disagreed that TH is effective as a conservation strategy. TH industry representatives viewed this as an effective strategy. Provincial wildlife authorities were split on the issue, and those with very direct roles in regulating the industry (e.g., the member of the judiciary and the national park/nature reserve employee), those engaged in research, advocacy, or monitoring of the industry (representatives of South African conservation/wildlife protection NGOs, the researcher/economist, and the researcher/environmental journalist) were more likely to have concerns or disagree that TH is an effective conservation strategy.

The second question asked whether the respondents had personally witnessed or experienced corruption in the TH industry. Six (40%) of the respondents said that they had directly witnessed or experienced corruption in the TH industry in South Africa. The types of corruption directly witnessed by these participants are summarized in

Table 2. Forms of perceived corruption directly witnessed by study participants.

Bribes or gifts offered by hunters to, or solicited by, administrative officials, outfitters, or community leaders to: ○ Expedite permits or handle permits after the fact instead of prior to hunting (2 respondents); ○ Allow access to preferred species or hunting areas (2 respondents); ○ Falsify documents related to numbers of animals taken and/or geographic locations where animals were killed (3 respondents); ○ Avoid prosecution for violations of the law (e.g., by bribing members of the judiciary for a favorable outcome for their case) (1 respondent). Forging permits and other documents: ○ To allow criminals involved in wildlife trafficking to obtain TH permits under false names (2 respondents); ○ Entering fraudulent entries into professional hunters’ registers or using different Certificates of Adequate Enclosure and certificate numbers than those on actual certificates (as the animals are hunted in areas not listed on the certificates) (1 respondent). Moving animals from one location to another to avoid prohibitions on TH in specific areas (1 respondent). Destroying evidence when hunters kill individuals that are not allowed to be hunted (e.g., those that are microchipped) (1 respondent).

. They described officials, outfitters, and community leaders soliciting bribes to expedite the permit process, providing access to preferred hunting grounds and species, and altering key details on documents used to legally certify a hunt (e.g., the number of animals killed or where the hunt took place). One participant explained that there is “a lot of quid pro quo going on in the industry in the form of free hunts, free meat, and basically anything else one would want can be swapped for the issuance of a permit”. They also witnessed animals being illegally moved from areas where hunting is prohibited to areas where it is permitted. One participant stated that they had “personally witnessed bribery [in the industry] ranging from the scale of just offering a can of Coke to offering ZAR 11 million” (approximately USD 606,000).

Answers to this question did not vary as much in conjunction with professional affiliation or roles in the industry, nor did responses to question 2 correspond directly with whether respondents thought TH was an effective conservation tool. One representative of a professional hunting association, two provincial wildlife authority officers, one representative of a South African conservation/wildlife protection NGO, one member of the judiciary, one national park/nature reserve employee, and one researcher responded that they had personally witnessed corruption in the TH industry in South Africa. On the other hand, one representative of a professional hunting association, three provincial wildlife authority officers, one researcher/economist, one wildlife rancher/wildlife specialist, and two representatives of South African conservation/wildlife protection NGOs responded that they had not personally witnessed corruption in the TH industry in South Africa.

Next, respondents were asked if they had heard about (but not directly witnessed) accounts of corruption in the TH industry. Thirteen of 15 (87%) respondents said that they had.

Table 3. Forms of perceived corruption heard about by study participants from others.

Bribery enabling abuse of the permitting system to: ○ Expedite the issuance of permits, delay to the issuance of permits unless a bribe is paid, or issue permits that include fraudulent information (4 respondents); ○ Get away with unethical and illegal practices such as killing the wrong animal or immature animals (1 respondent); ○ Using a legal permit for problem animal control as a cover for an illegal trophy hunt (1 respondent); ○ Allow international export of trophies even while the permit contains falsified information, which may constitute wildlife trafficking (2 respondents); ○ Allow for re-use of microchips in trophy hunted lions to obscure additional illegal kills and avoid reporting requirements (1 respondent). Corruption among enforcement authorities and judiciary: ○ Police and environmental conservation officers being investigated for their involvement in corrupt practices related to the TH industry (2 respondents); ○ Cases investigating corruption in the TH industry have gone to court, but no prosecutions have taken place (1 respondent). ○ Investigative reports issued showing even suspicious hunts as totally legal (1 respondent) Lack of transparency and industry influence over government policies: ○ Massive influence of the TH industry and outright refusal to be transparent on the part of the government renders it impossible to ascertain how permits were obtained (2 respondents) ○ Funds from trophy hunts going to offshore accounts with little or no transparency for how the money is spent or how it may ultimately benefit local communities (1 respondent).

summarizes the forms of corruption respondents had heard about from others. Many of these accounts were related to abuse of the permitting system, with one respondent stating: “There is quite a lot of room for corruption in the permitting system. Individuals have hunted on farms that do not have Certificates of Adequate Enclosure and [then] use a certificate from another farm to fill in the register after the fact, and even ship the trophies overseas based on that permit. Bribery is involved in such cases”. Another respondent stated that “trophies are trafficked through the South Africa trade system, with operators paying off taxidermists to fabricate paperwork for [trophy hunted] animals”.

Only two respondents (one representative of a professional hunting association and one provincial wildlife authority officer) stated that they had neither witnessed corruption in the TH industry in South Africa nor heard of any such incidents. One stated that there were “…one or two incidents over 25 years, but only unproven allegations”. All the other participants, including those employed within the TH industry and those who think that TH is an effective conservation strategy, reported hearing about instances of corruption.

Respondents were then asked whether they think that the corruption they had witnessed or heard about influences the practice of TH in South Africa. The same two respondents (one representative of a professional hunting association and one provincial wildlife authority officer) who responded that they had neither personally witnessed corruption nor heard of any such incidents occurring within the industry maintained that corruption does not influence TH. Another respondent said it is not a major issue in South Africa (but may be in other African countries), and another argued that the media blows incidents of corruption out of proportion. The remaining eleven respondents (73%) asserted that corruption did have an influence, with one stating that “TH is ‘sold’ as an ecological management tool, but social media and exposés show the corrupt nature of the industry, and it’s caused global outcry, and it’s negatively affected the image of TH”. The perceptions of those who felt that corruption did have an influence on TH are summarized in

Table 4. Perceived influence of corruption on the practice of TH in South Africa.

Calls into question claims of conservation benefits of TH: ○ Opacity of the permitting process allows for corruption and renders data inaccurate (5 respondents); ○ Negatively affects the industry by reducing its possible conservation benefits (3 respondents); Abuse of the permitting system results in poaching and trafficking, sullying the image of TH and indicating it is an industry where the primary goal is to make money and laws are broken in this pursuit (2 respondents) Corruption and related practices cause a rift within the TH industry

below.

The next question focused on whether there are particular sub-industries or stakeholders in the TH industry who are more likely to engage in corrupt or illegal TH practices. There was a variety of responses to this question, with most respondents mentioning provincial authorities, landowners, and TH outfitters as responsible for potential corruption in the industry. South African conservation/wildlife protection NGOs tended to respond that provincial wildlife authorities enabled corruption, while a wider array of respondents stated that landowners and TH outfitters are more likely to engage in corrupt practices.

Table 5. Are there particular sub-industries or stakeholders among whom corruption or related practices seem to be most problematic?

Stakeholder	Number of Respondents	Percentage of Total
Provincial wildlife authorities	7	46.67
Landowners	6	40.00
Trophy hunting outfitters	5	33.33
Taxidermists	3	20.00
High-level government officials	3	20.00
Professional hunters	2	13.33
None	2	13.33
Trophy traders	1	6.67
All actors in the industry	1	6.67
Biltong * makers	1	6.67
Professional hunters’ associations	1	6.67

Note: Respondents were allowed to select more than one response. * Biltong is a form of dried, cured meat sometimes made from wild animal meats.

summarizes these responses.

Respondents were next asked what, if any, structural issues exist that enable corruption to occur within the TH industry in South Africa. Responses to this question are summarized in

Table 6. Are there structural issues that enable corruption within the TH industry in South Africa?

Structural Issue	Respondents	Percentage of Total
Permitting system is ineffectual, flawed and easily exploitable	8	53.33
Lack of capacity among enforcement/permitting officers	6	40.00
Corruption is pervasive in high levels of government	5	33.33
System that dictates wildlife laws and regulations is only accessible by the TH industry	5	33.33
Ineffective judicial system	4	26.67
Lack of governance and poor administration of laws that govern TH	3	20.00
Inconsistent provincial and national laws on TH	3	20.00
Incentives exist for corruption among landowners to maintain the status quo	3	20.00
Wildlife crimes are seen as petty crimes	2	13.33
TH industry is driven by greed	2	13.33

Note: Respondents were allowed to select more than one response.

. Once again, a wide variety of responses were received. Eight participants indicated that the permitting system is inefficient, flawed, and/or easily exploitable by corrupt individuals. The permitting system was specifically flagged as problematic by two researchers, one member of the judiciary, three representatives of South African conservation/wildlife protection NGOs, one provincial wildlife authority officer, and one wildlife rancher/wildlife specialist.

Six respondents mentioned a lack of capacity among enforcement and/or permitting officials to enforce laws against corruption in the industry or to handle the permit workload, respectively. This weakness was mentioned by one representative of a professional hunting association, one member of the judiciary, three provincial wildlife authority officers, and one representative of a South African conservation/wildlife protection NGO. One respondent stated that “TH is mixed in with mafia dealings and money laundering, foreign currency, and foreign nationals, so there are many opportunities for fraud, corruption or criminality to occur”.

Five respondents said that corruption is pervasive at every level of South African society, and one respondent said that it is “very difficult to mitigate corruption when corruption goes all the way up to levels like the President”. That same respondent also stated, “the problem lies within the community itself; there must be no tolerance of corruption and people must report it when they see or hear of it. Ordinary citizens that would rather make their problems go away by offering a bribe are the problem; but this is a cultural issue”. Another respondent argued that “the sheer scale of the [TH] industry in South Africa renders it impossible to enforce effectively considering the staffing and funding limitations” of authorities. Three respondents (one representative of a professional hunting association, one provincial wildlife authority officer, and one representative of a South African conservation/wildlife protection NGO) also highlighted inconsistencies in provincial wildlife regulations and a lack of a national legislation to regulate TH as examples of specific structural issues that enable corruption.

The next question asked whether respondents were aware of efforts or structures in place that aim to mitigate corruption in the TH industry. Eight respondents said they were aware of mitigation strategies. Efforts and structures mentioned included the Hawks (the branch of the South African Police Service which investigates organized crime, corruption, and other serious crimes), training courses on combatting corruption for relevant government officers, self-regulation by the TH industry, the transparent and inclusive nature of TH processes in some provinces, and hotlines to report corruption or bribery in the industry. Seven respondents said they were not aware of such efforts or structures or that existing mitigation efforts were ineffective and/or insignificant, including three representatives of South African conservation/wildlife protection NGOs, two researchers, one wildlife rancher/wildlife specialist, and one provincial wildlife authority officer.

Next, respondents were asked what they think can be done to mitigate corruption in the TH industry in South Africa. The mitigation strategies suggested by participants are summarized in

Table 7. What can be done to mitigate corruption in the TH industry?

Structural Issue	Respondents	Percentage of Total
Build enforcement capacity	4	26.67
Increase transparency and accountability of the TH industry	4	26.67
Strategic legislation to force accountability in the TH industry	2	13.33
Self-regulation by the TH industry	2	13.33
Establish a secure, national electronic permitting system	2	13.33
Hunter education and training	2	13.33
National legislation that unifies provincial TH regulations	2	13.33
Nothing is needed	1	6.67
Disciplinary tribunal for corrupt trophy hunters	1	6.67
Increase awareness of structures in place to mitigate corruption in the industry	1	6.67
Training prosecutors with police and wildlife authorities	1	6.67
Dedicated prosecutors for corruption cases	1	6.67
Better population estimates for TH target species	1	6.67
Establishment of an independent watchdog authority	1	6.67
Ordinary citizens must report corruption	1	6.67
Base TH decisions on science	1	6.67
Permanent license revocation for professional hunters who break the law	1	6.67
Enact EU laws to better govern the import of trophies (similar to US laws)	1	6.67
Ban TH	1	6.67

Note: Respondents were allowed to select more than one response.

. The most popular mitigation strategies recommended by respondents involved building enforcement capacity (27%) (including increased funding, staffing, training) and building transparency around the practice of TH (27%). Specific suggestions for building transparency included instituting a national electronic permitting system that would be less vulnerable to exploitation. Others indicated the need for a national law to unify the disparate provincial wildlife regulations governing TH. A total of 13% of respondents favored increased hunter education and training or self-regulation by the TH industry.

Respondents associated with the TH industry and professional hunting organizations tended to favor mitigation strategies involving industry self-regulation (e.g., hunter education, establishing a disciplinary tribunal that would allow TH industry professionals to censure bad actors and enforce existing industry codes of best practices, etc.). Respondents working as provincial authorities favored strategies that involved increasing the South African government’s capacity to regulate the industry and/or enforce existing laws (e.g., reforming the permitting system and harmonizing provincial laws into a consistent national-level policy). Most respondents indicated that actions could be taken to reform the TH system; only one respondent favored banning TH entirely. Two representatives of South African conservation/wildlife protection NGOs, one provincial wildlife officer, and one member of the judiciary suggested building the enforcement capacity. One PH association representative said that nothing is needed, while another suggested the TH industry self-regulation and a disciplinary tribunal for trophy hunters that are involved in corruption. One provincial wildlife authority officer, two representatives of South African conservation/wildlife protection NGOs, and one researcher/economist suggested increasing the transparency and accountability of the TH industry.

One respondent suggested that South African laws will always be ineffective for regulating the industry, and external pressures or reforms may be the best avenue to enact change. To combat corruption in the TH industry in South Africa, the European Union should be lobbied to implement trophy import regulations like those of the United States (e.g., the Endangered Species Act specifies additional regulations on the import/trade of materials from endangered or threatened species and the Lacey Act prohibits the trade in illegally taken wildlife, fish, and plants).

Finally, respondents were asked whether they think South Africa’s TH industry leads to poaching and trafficking, in the sense that corruption in the industry may lead to a violation of international laws governing trade and the export/import of products associated with endangered or threatened species. For example, a trophy hunter could theoretically violate trade law by exporting a hunting trophy of a protected animal species for which permits were fraudulent to a foreign country. Nine respondents (60%) said that they think it does, four respondents (27%) said that they did not think it does, and two (13%) were unsure whether it does or not. One respondent stated that “Big trophy fees lure professional hunters to break the rules and the law, including shipping trophies overseas, which constitutes trafficking if the paperwork is falsified”. Another stated that “corruption enables hunters to conduct trophy hunting where they shouldn’t be able to, which results in illegal hunting”. Still another respondent stated that “TH permits are not offered to local communities, and so inequity breeds demand for poaching”.

Overall, 33% of respondents (one member of the judiciary, one national park/nature reserve employee, one provincial wildlife authority officer, one representative of a South African conservation/wildlife protection NGO, and one representative of a PH association) viewed corruption as pervasive in South Africa even in high levels of government. More than half of respondents felt that the TH industry is at least vulnerable to corruption, even if they did not necessarily agree that it is “pervasive”. For example, 53% (one national park/nature reserve employee, one provincial wildlife authority officer, one researcher/economist, one researcher/environmental journalist, three representatives of South African conservation/wildlife protection NGOs, and one representative of a PH association) felt that the permitting system is flawed and easily exploitable by corrupt individuals, with some citing a lack of transparency. A total of 33% of respondents (one national park/nature reserve employee, one researcher/economist, and three representatives of South African conservation/wildlife protection NGOs) said that the system that dictates wildlife laws is only accessible to the TH industry, encouraging corruption in favor of the industry. A total of 40% of respondents (one member of the judiciary, three provincial wildlife authority officers, and one representative of a PH association) mentioned the lack of capacity among enforcement and/or permitting officials and a lack of deterrents to prevent corruption, including an ineffective and easily exploitable judicial system, providing an ideal environment for corruption to thrive.

Most respondents felt that corruption negatively influences TH in South Africa, including undermining the potential conservation and community benefits, enabling the link between TH and trafficking of trophies out of South Africa, and tarnishing the image of TH by associating it with organized crime.

4. Discussion

Despite this study’s many limitations in terms of time constraints and recruitment, it appears from the data collected that reform may be necessary to address the potential for corruption within the TH industry in South Africa. Only two respondents (one professional hunting association representative and one provincial wildlife authority) denied that corruption has an influence on TH in South Africa. The other 13 participants, including respondents whose livelihoods depend on TH, reported some level of concern about structural weaknesses in the system that could allow for corruption. Those most directly involved in regulating the industry and conducting research to assess the efficacy of TH as a conservation strategy expressed the most acute concerns. Most of these stakeholders within the TH system acknowledged that preventing corruption is desirable to protect the image of the industry, safeguard wildlife, and/or ensure that the possible conservation and economic benefits of TH are fully realized. Further research is needed to determine exactly how pervasive the different forms of corruption reported by these respondents are within the industry; however, their observations provide a window on key aspects of the TH system that may be particularly vulnerable to corruption as well as possible strategies for mitigating corruption in the system.

In terms of structural reform, study participants identified three possible avenues for change: (1) improving government regulation (e.g., policy harmonization and more funding to increase enforcement capacity); (2) creating additional avenues for industrial self-regulation (which was usually framed by those in the TH industry as an alternative to government-led regulation); and (3) strengthening laws in the countries where trophies are imported to make it harder for hunters to bring home illegal trophies (e.g., requiring more scrutiny of permits and paperwork and/or banning the importation of some species entirely). A combination of all three approaches may be necessary to reduce opportunities for corruption and improve conservation and economic outcomes associated with TH.

In terms of improving government regulation, participants identified the TH permitting system as a primary target for reform. According to study participants, the current permitting system can be easily exploited by those seeking bribes, and paperwork can easily be altered or forged. Vulnerabilities in the permitting system also make it difficult to track the number of animals being hunted and exported, data that are essential for determining whether TH is ecologically sustainable. They suggested an electronic permitting system could prevent some of these opportunities for corruption. This is consistent with the changes recommended by Johanisová and Mauerhofer [45] based on their findings regarding discrepancies between the number of reported kills and the trophies exported from South Africa. Permitting and record-keeping practices should be a key focus for improvement.

Most participants also regarded many aspects of the regulatory apparatus surrounding TH as non-transparent, dominated by too few stakeholders, and/or too inconsistent between provinces. They pointed out an immediate need to harmonize provincial laws related to TH and/or create a more coherent national-level policy that would supersede inconsistent provincial regulations. Participants also desired public access to information about how regulatory decisions are being made and how policies are being enforced, as well as greater influence within this process. Participants with a science background also requested public access to accurate, real-time data about TH so that they could accurately assess how wildlife populations may be affected. Previous studies (e.g., [50,51]) suggested that multi-stakeholder involvement in decision making is important for ensuring that the economic benefits of TH are equitably distributed and the conservation benefits are fully realized. This research also suggests that revised TH policies should place a greater emphasis on transparency and public engagement at local, regional, and national levels. Harmonizing regulations, instituting an electronic permitting system, and creating greater transparency within the regulatory apparatus will have a more profound effect than injecting additional funding into a flawed system.

Improved industry self-regulation could also be part of a multi-pronged strategy for addressing corruption within TH. Based on qualitative research conducted among TH stakeholders in Zimbabwe, Njerekai and Mabika [56] recommend a suite of solutions to help create professional standards and close loopholes in the industry. These include the development of an accreditation or certification scheme for TH operators to encourage best practices and allow operators to identify and censure operators who violate industry standards. Wanger et al. [57] also propose an adaptive certification scheme for TH operators routed through CITES as a solution for improving the sustainability of the industry and holding operators accountable to ethical standards. Self-regulation was favored by representatives of professional hunting associations interviewed in this study, but most study participants favored further government regulation.

Respondents who perceived TH as hindered by corruption noted that this is not unusual because corruption in general is considered rife within the country [33,34], including within enforcement authorities [37]. They also regarded anti-corruption agencies within the country as largely ineffective [34]. Further, anti-corruption enforcement has been politicized to the point that such efforts are frequently compromised or sidelined [58], causing some to doubt whether it is possible to mitigate corruption through reform within South Africa. To this end, strengthening laws in the countries where trophies are imported could also be an effective part of a multi-pronged strategy for improving conservation outcomes associated with TH.

Only one participant recommended a ban on TH. Further research is needed to understand public attitudes toward TH in South Africa, and this study was not designed to assess perspectives on whether TH should be banned. Because this study was designed to examine the possible influences of corruption on TH, participants primarily focused on how TH could be effectively managed as an integral part of South Africa’s conservation strategy.

5. Conclusions

The results of this study suggest that there are aspects of the TH system in South Africa that are vulnerable to corruption, and many stakeholders involved in TH see corruption as a potential threat to the industry. Respondents across all categories of stakeholders interviewed (including those from groups that are publicly staunch supporters of TH) had witnessed or heard of corruption in the TH system, expressed some level of concern based on these observations, and offered compelling suggestions about how to mitigate the possible influence of corruption on TH. Those more intimately involved in regulating the industry and/or collecting empirical data used to evaluate the ecological and economic effects of TH expressed more acute concerns.

Previous researchers (e.g., [44]) identified some of the very general forms of corruption that trouble the TH industry in Africa, but the results of this study (1) pinpoint the specific nodes in this system that are particularly vulnerable to corruption in South Africa, and (2) perhaps most importantly, identify potential strategies for mitigation that local stakeholders think would be the most meaningful and effective. Although the types of corruption identified by respondents were noted previously, this study provides additional context for understanding the structures that allow these forms of corruption to persist and how the system could be adjusted to make TH more effective as a conservation and economic development strategy for South Africa.

In South Africa, the weakest points in the TH system appear to be the permitting/reporting system, the process used to identify and prosecute violations, inconsistency across provincial regulations (with provincial authorities high on the list of those most likely to engage in corruption), poor coordination among agencies and authorities, few formal opportunities for industrial self-regulation (e.g., training for TH operators and landowners and/or an accreditation system to standardize and promote ethical practices), and a lack of transparency in the decision-making process that alienates some stakeholders and creates distrust in the system.

Based on these data, we recommend a multi-pronged approach to eliminating the opportunity for corruption within the TH system in South Africa. Building on the suggestions made by study participants and previous studies on TH, we recommend: (1) improving permitting and record-keeping procedures, ideally by creating and maintaining a secure national electronic permitting system; (2) harmonizing provincial policies to eliminate inconsistencies and opportunities/incentives for corruption on the part of provincial authorities; (3) prioritizing transparency and multistakeholder engagement in the regulatory process, including enhancing public access to data used to make decisions regarding TH quotas and permit issuance; (4) bolstering self-regulation strategies for TH operators, such as creating an accreditation or certification scheme to help enforce strong ethical standards within the industry; and (5) working with the European Union to strengthen policies regulating the trade in products from threatened and endangered species.

Despite the small sample size, the perspectives of the stakeholders who participated in this study are valuable for identifying how corruption potentially effects TH in South Africa and how these influences could be mitigated. Further research with a larger sample size is needed to examine the pervasiveness of corruption in the industry, as well as important variations in the way that stakeholders perceive and experience possible forms of corruption in different areas. Qualitative research focused on local perceptions of TH is critical for determining how best to regulate this industry. Most respondents felt that TH has a role to play in conserving wildlife. It is clear from this research, however, that system reform is needed to deal with both real and perceived corruption in the TH industry. Such reform can surely only improve wildlife conservation in South Africa.