Position statement on UNODC Wildlife and Forest Crime Analytic Toolkit Report

On 17th December 2021 the United Nations Office on Drugs and Crime (UNODC) Wildlife and Forest Crime Analytic Toolkit Report was published by Defra on the GOV.UK website, HERE (it is currently available for download from HERE). The UK is the first of the G7 countries to request this Toolkit Assessment by the International Consortium on Combating Wildlife Crime, which demonstrates the UK’s leadership in this field. The report provides an overview of the legislation, enforcement and judicial approach in the UK, followed by analysis of the challenges experienced by the seven wildlife crime Priority Delivery Groups (PDGs). Bat crime is one of the seven wildlife crime priorities. The report makes a series of general, and PDG specific, recommendations.

BCT’s Wildlife Crime Project provides support to the police, Crown Prosecution Service, ecologists and members of the public during wildlife crime investigations. For every case that goes to court we provide a Conservation Impact Statement and, in some cases, we provide information relevant to a Proceeds of Crime Act (POCA) confiscation. Indeed, the UNODC report stated: There appears to be a greater willingness to utilize proceeds of crime applications in the context of bat crime, which is encouraging and reveals an appreciation of the deterrent effect of such orders within this context.[1]

BCT is the Secretariat and plays a very active role on the Bat PDG, contributes to the Wildlife and Countryside Link Wildlife Crime and Trade Group, contributes to the Crown Prosecution Service Community Panel and was interviewed in relation to the UNODC report.

There are three specific recommendations in the UNODC report in relation to bat crime, as follows:

  • Guidelines should be issued for the use of POCA applications in this context, particularly in relation to commercial developers. So far, POCA applications have not been based on profits but rather focus on the costs avoided, for example. As a strategy, the prosecution authorities across the UK should adopt a unified approach with the requisite prosecution departments sensitised and briefed accordingly, and the financial investigation capacity of the National Wildlife Crime Unit (NWCU) enhanced.
  • Where confiscation orders are made in this context, it is recommended to make them available for conservation gain. This may require a change in the law or regulations governing the proceeds of crime.
  • There is excellent work going on across the UK in terms of public information and campaigns, particularly informing developers/homeowners of their obligations regarding bats and bat roosts. Targeted funding for specific conservation crime prevention work should be assigned for police and other organisations, including NGOs such as the Bat Conservation Trust (BCT) which operates a National Bat Helpline offering advice and guidance on bat welfare/offences.[2]

Many of the general recommendations in the report are also relevant to bat crime, including:

  • Move the funding for the National Wildlife Crime Unit (NWCU) to the Home Office and establish the Unit on a permanent basis.
  • Significantly increase the annual budget of the NWCU to enable the hiring or seconding of additional staff and the purchase/lease of vehicles and equipment.[3]
  • Make it a legal requirement for all constituent governments to provide data and analysis on the enforcement, prosecutions and outcomes for wildlife crimes, including relevant stakeholder data, for a comprehensive annual report on wildlife crime, such as that produced by the Scottish Government. This will result in all criminal justice agencies frequently and consistently reporting and publishing wildlife crime data.
  • Make all wildlife crimes recordable and notifiable offences, with discrete wildlife crime codes to reduce ambiguity and disparity between nations. This will enhance data granularity and reduce the ‘dark figure’ of wildlife crime.[4]

All involved should be held to account for these recommendations, especially those individuals, organisations and civil services who were represented and/or contributed to the UNODC report. To achieve accountability, the Home Office and Defra should be leading from the very top, setting an example by making wildlife crime notifiable and recordable and issuing a directive to address the other recommendations. However, the UNODC report does not promote accountability from these departments, a response such as that described above has not been forthcoming and the report has not been widely publicised.

The Bat PDG and many other NGOs had already recognised and provided evidence on these topics, and had indeed been working on solutions prior to the publication of the report. The Bat PDG have now adapted their work plan to be specific to the report recommendations.

There is clear evidence that making our environment welcoming to wildlife benefits our own physical and mental wellbeing. We need to continue to work together to protect our natural heritage in both rural and urban settings so that present and future generations can benefit.

[1] Page 91 WILDLIFE AND FOREST CRIME ANALYTIC TOOLKIT REPORT United Kingdom of Great Britain and Northern Ireland August 2021.

[2] Page 27 WILDLIFE AND FOREST CRIME ANALYTIC TOOLKIT REPORT United Kingdom of Great Britain and Northern Ireland Executive Summary August 2021.

[3] Page 20 WILDLIFE AND FOREST CRIME ANALYTIC TOOLKIT REPORT United Kingdom of Great Britain and Northern Ireland Executive Summary August 2021.

[4] Page 23 WILDLIFE AND FOREST CRIME ANALYTIC TOOLKIT REPORT United Kingdom of Great Britain and Northern Ireland Executive Summary August 2021.