Exhibition or Exploitation?

EXHIBITION OR EXPLOITATION? THE LEGAL YET UNETHICAL AND LOW-WELFARE PRACTICE OF KEEPING AND TRAINING WILD ANIMALS FOR EXHIBITION OR PERFORMANCE IN ENGLAND, SCOTLAND AND WALES EXPOSED Published: November 2021

CONTENTS 2

Foreword

3

Report Summary

4

Introduction

7

Key Findings

12

Spotlight on Species and Animal Groups of Concern

20

Why is Current Legislation Not Protecting These Animals?

23

Recommendations

24

Acknowledgements

24

Copyright Statements

25

References COVER STORY Thousands of wild animals are legally kept or trained for exhibition or performance in Great Britain, including more than 4,300 reptiles, 3,900 birds, 2,400 mammals, 1,790 amphibians and more than 280 fish. A further 6,290 invertebrates are used for this purpose. Shown at events, handled by members of the public, photographed, and filmed for entertainment, these wild animals face a life of compromised welfare.

Born Free Foundation 2nd Floor, Frazer House 14 Carfax, Horsham West Sussex, RH12 1ER, UK bornfree.org.uk Registered charity 1070906

FOREWORD

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Will Travers OBE, Co-founder and Executive President, Born Free Foundation “The use of wild animals for exhibition or performance should provoke the same critical response as the use of wild animals in travelling circuses, rightly banned in Great Britain after decades of sustained pressure and effective campaigning by Born Free and others.

However, thousands of wild animals are legally used for exhibition or performance in England, Scotland and Wales. Children and adults, across the nation, are encouraged to attend and participate in shows and activities that exploit wild animals, including many hundreds of reindeer in the run up to Christmas.

And whilst we have moved on from performing chimpanzees advertising tea in the 1980s, captive wild animals are still in regular use in advertising, TV and film.

As this latest Born Free report shockingly reveals, the welfare of these animals is compromised, and normalising the use of wild animals as entertainment presents real risks to animals and people alike. Born Free is calling on the Government to prohibit this low-welfare practice which impacts the lives of thousands of wild animals. We rightly said “no” to circuses. We’ve all but prohibited the UK’s domestic trade in ivory. There are no more captive dolphins. The Government has pledged to end trophy hunting imports. Now we must unite against the outdated and immoral practice of using live, wild animals in performance and exhibition, and we ask the public to help end demand by undertaking not to go to a facility which exploits wild animals in this way. We are a nation of animal lovers. Let’s prove it once more. Stop captive wild animal exploitation - and keep wildlife in the wild, where it belongs.”

EXHIBITION OR EXPLOITATION?

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REPORT SUMMARY While the use of wild animals in travelling circuses has been widely regarded as ethically unacceptable in Great Britain for decades, resulting in a prohibition on the use of wild animals for this purpose on ethical grounds in England, Scotland and Wales in recent years, the use of wild animals for other types of exhibition or performance has not been given equal consideration.

This report examines the scale, scope and nature of the legal use of wild animals* for exhibition or performance in Great Britain.

Key Findings l

More than 11,470 wild vertebrate animals were included on licences to keep or train animals for exhibition in England under The Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018 between 1st October 2018 and 31st October 2020.

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Over 1,200 wild vertebrate animals were registered to be exhibited or trained for performance in Scotland and Wales under the Performing Animals (Regulation) Act 1925 between 1st January 2000 and 31st October 2020.

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Wild animals in all five vertebrate classes were represented, including more than 2,400 mammals, 3,900 birds, 4,300 reptiles, 1,790 amphibians, and 280 fish. A further 6,290 invertebrates were being kept or trained for exhibition or performance by licensed or registered operators.

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Commonly used species included reindeer, meerkats, African pygmy hedgehogs, Harris’s hawks, barn owls, cockatiels, corn snakes, bearded dragons, royal pythons, axolotls, White’s tree frogs, and African bullfrogs.

• Types of exhibition or performance were wide-ranging, and included: TV, film, radio, social media, photo shoots, advertisements, music videos, circus performances, magic shows, theatre, animal encounters, exhibition on site, exhibition at external events, bird flying shows, falconry, falconry training courses and animal-assisted therapy.

• Animal encounters, involving handling of wild animals by members of the public, were by far the most common type of exhibition or performance, with over 77% of operators offering this activity.

Key Messages Current legislation is failing to protect these animals. Used for exhibition or performance in their thousands, these animals are non-domesticated and evolved in complex wild environments, making them unsuited to life in captivity. Their many captivity-associated health and welfare problems are well-evidenced, and they face further welfare compromise when used in exhibition or performance settings. Often kept in unsuitable environments, they are frequently exposed to unfamiliar and unnatural situations, handled by unfamiliar and untrained members of the public, subjected to welfare-compromising husbandry practices to make them more amenable to exhibition and, for nocturnal (active at night) and crepuscular (active at dawn and dusk) animals, required to perform at times of the day when they would naturally be resting.

Born Free is calling on the UK government, Scottish Parliament, and Welsh Parliament to: l

Introduce a prohibition on the use of wild animals for exhibition or performance. The low-welfare practice of keeping and training wild animals for these purposes, has serious negative impacts on the lives of many thousands of wild animals, and should have no place in modern society.

Born Free is calling on event organisers, the media industry, venue operators and owners and wider members of the public to: l

Pledge not to use or patronise facilities that use wild animals for exhibition or performance. By reducing the demand for these live wild animals to perform, members of the public can play an important role in reducing the scale of this significant welfare issue.

* “Wild animal” means an animal not normally domesticated in Great Britain.

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INTRODUCTION PERFORMING WILD ANIMALS IN GREAT BRITAIN – BEYOND TRAVELLING CIRCUSES In 2020, in recognition of the ethically unacceptable practice of using wild animals in travelling circuses, the UK and Welsh governments enforced a long-awaited, and much needed, ban on the use of wild animals in travelling circuses in England and Wales.1-4 This followed the introduction of a similar prohibition on the use of wild animals in travelling circuses in Scotland in 2018.5,6 However, this milestone, while hugely significant, by no means marked an end to the use of wild animals for exhibition or performance in Great Britain.

Wild animals continue to be legally kept and trained for exhibition in England by a multitude of operators licenced under The Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018 (hereby referred to as the LAIA Regulations 2018),7 and exhibited or trained for performance in Scotland and Wales by operators registered under the Performing Animals (Regulation) Act 1925.8 Under the LAIA Regulations 2018, ‘exhibition’ refers to exhibition in the course of a business for educational or entertainment purposes (a) to any audience attending in person, or (b) by the recording of visual images of them by any form of technology that enables the display of such images.7 ‘Performing animals’ and ‘performance’ are not defined in the Performing Animals (Regulation) Act 1925; however, the Act does not apply to the training of animals for bona fide military, police, agricultural or sporting purposes, or the exhibition of any animals so trained.8 The RSPCA defines 'performing animal' as any animal that is taken away from its usual home environment or social group or that is trained/set up to behave in a particular way for a production.9 For the purpose of this report, the terms ‘exhibition’ and ‘performance’ are used synonymously to describe activities licensed under a LAIA Regulations 2018 exhibition licence or registered under the Performing Animals (Regulation) Act 1925. Operators licensed under the LAIA Regulations 2018 and registered under the Performing Animals (Regulation) Act 1925 come in many guises - providing wild animals for TV, film, social media, photo shoots, flying shows, private and public events. However, the true extent of the keeping or training of wild animals for exhibition or performance in England, Scotland and Wales remains poorly understood.

This continuing legal use of wild animals is cause for great concern. Wild animals have varied, complex needs which are challenging to meet when they are kept in captive environments.10 The keeping and training of wild animals for exhibition or performance presents further challenges to the welfare of the captive wild animals involved. Akin to animals in travelling circuses, animals may be subjected to unnatural husbandry and training practices intended to make them more amenable to exhibition or performance; regularly exposed to handling and unfamiliar environments, people, and other animals; and repeatedly confined to small, temporary enclosures during transport or when held at exhibition or performance locations.

It is vital to understand which wild animals are being kept or trained for exhibition or performance, and how they are being kept and exhibited, in order to make policy recommendations to ensure the good welfare of these animals or prohibit their use if that use is incompatible with good welfare.

In this investigation, we aimed to unearth the scale and scope of the legal keeping and training of wild animals for exhibition or performance under the LAIA Regulations 2018 in England, and under the Performing Animals (Regulation) Act 1925 in Scotland and Wales, in order to make policy recommendations to protect the welfare of the wild animals involved in the exhibition and performance industry.

OUR INVESTIGATION: DATA COLLECTION AND ANALYSIS Data collection: England Under the Freedom of Information Act 2000, we requested copies of all licences issued to operators to keep or train animals for exhibition under the LAIA Regulations 2018 between 1st October 2018 and 31st October 2020 from all 317 local licensing authorities in England, alongside copies of all inspection reports submitted by inspectors to each local licensing authority following inspection of operators applying for a licence over the same period. The study start date (1st October 2018) was chosen as the LAIA Regulations 2018 came into force in England on this date. Local Authorities were also asked to provide information regarding the type, frequency and approximate duration of performances, as reported by each operator in their licence

EXHIBITION OR EXPLOITATION?

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application form. Information regarding the species or species groups that may be used for performances, and the maximum number of animals of each species or species groups that may be used for performances, was also requested separately, if not clearly stated in the licences.

Responses to the information requests submitted under the Freedom of Information Act 2000 were provided by 304 of the 317 local licensing authorities in England (96% response rate). Where insufficient information was provided by Local Authorities to determine the species or species groups kept or trained for exhibition by licensed operators, or the types or duration of performances provided by these operators, publicly available information was retrieved from the websites or social media sites of the operators.

Data collection: Scotland and Wales A copy of the Performing Animals (Regulation) Act 1925 register, to include all persons who registered between 1st January 2000 and 31st October 2020, was requested by email under the Freedom of Information Act 2000 from all 32 Local Authorities in Scotland, and all 22 Local Authorities in Wales, along with information relating to the animals to be trained or exhibited and the general nature of the performances, if not included in the copy of the register. In Scotland and Wales, operators need only register once with their Local Authority in order to exhibit or train performing wild animals under the Performing Animals (Regulation) Act 1925, and no inspection process is required.8 A twenty-year period beginning 1st January 2000 and ending 31st October 2020 was chosen as the study time period, since preliminary investigations showed that some businesses in operation at the time of the study had been in operation since 2000. Although it is not a legal requirement, preliminary investigations indicated that at least one Local Authority was carrying out inspections prior to registration, therefore each Local Authority was also asked whether they carry out any inspections of the premises where animals are housed as part of the registration process and, if so, who carries out the inspections. Copies of any inspection reports submitted by inspectors to each Local Authority over the same time period were also requested.

Responses to the information requests submitted under the Freedom of Information Act 2000 were provided by all Local Authorities in Scotland and Wales (100% response rate). Where insufficient information was provided by Local Authorities to determine the species or species groups trained or exhibited for performance by registered operators, or the types or duration of performances provided by these operators, publicly available information was retrieved from the websites or social media sites of the operators.

Data analysis: species / species groups We only included wild animals, defined as “any animals not normally domesticated in Great Britain” in our study population. Where the number of animals of a species or species group was unclear, we applied conservative data correction as follows: if no numerical information was available, the species or species group was analysed on the basis of a single animal; if there were multiple animals of a species or species group but the number was unknown, the species or species group was analysed as though there were two animals; if an estimated number of animals of a species or species group was provided by a Local Authority, the estimated number was used; if a plus sign was used after a number (e.g. 10+), the number given prior to the plus sign was used (i.e. 10 in this case); if offspring were included after a number (e.g. 5 plus offspring), only the number was used (i.e. 5 in this case); if a total number was provided for a group of several species or a group of several species groups, the total number was divided equally among the species or species groups, rounded down to the nearest whole number.

Data analysis: performance types Categories of performance type were assigned to each operator to best describe all of the different types of performance that the operator provided. If an operator provided multiple performances which were all best described as the same category, the operator was only assigned the category once. The categories of performance type were: TV; film; radio; social media; photo shoots (including: photo shoots for books, magazines or fashion; private photo shoots; and photo shoots as part of a photography club or workshop); advertisements; music videos; circus performances; magic shows; theatre; animal encounters (defined as any display to an audience in-person which involves handling by members of the public, excluding displays that fall within other categories); exhibition on site (defined as any display to an audience in-person on the site where the animal is housed, without public handling and excluding displays that fall within other categories); exhibition at external events (defined as any display to an audience in-person at off-site events, without public handling and excluding displays that fall within other categories); bird flying shows; falconry (defined as hunting wild animals in their natural state and habitat by means of a trained bird of prey); falconry training courses; and animal-assisted therapy (where “animal-assisted therapy” was either stated as one of the performance types provided by the operator or the performance was described as using animals to provide therapy to humans for mental and/or physical health benefits).

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Data analysis: duration of performances The duration of the shortest and longest performances provided by each operator were analysed, where known.

If a single performance duration was reported for an operator, this was analysed as both the shortest and longest duration of performance for that operator. Where the duration of performance was reported as “whole day”, this was analysed as 8 hours; “half day” was analysed as 4 hours; and “a few hours” and “several hours” were analysed as 2 hours. Where an operator specified that individual animals may only be exhibited for a particular duration of time within a performance, the duration of time that individual animals may be exhibited for was analysed. However, if an operator stated that rotation of animals and/or rest periods of unknown length were provided for individual animals within the total duration of a performance, the total duration of the performance was analysed as the use of rotation and/or rest periods implied that the same animals were later used again within the same performance.

The maximum number of performances provided by an operator per day was analysed, where this information was known. If an operator stated that they provided multiple performances per day, but each animal was only included in one performance per day, this was analysed as one performance per day.

Data analysis: inspection reports Inspection reports provided by Local Authorities in England were analysed to determine which LAIA Regulations 2018 general and specific licence conditions were not being met in full at the time of inspection. General licence conditions 1.0 and 1.2 were excluded from analysis as all operators were first-time applicants for a licence.11 General licence condition 2.2 was excluded from analysis if the inspector indicated that this condition was not met because the operator had not started trading yet.11 As our study concerned only wild animals, if a licence condition was not met in full for the domestic animals kept or trained by an operator, but it was otherwise met for the wild animals kept or trained by the operator, then it was considered to be met in full. Licence conditions not met in full at the time of inspection included those marked by the inspector as met, where this was dependent on a change to current practice following the advice of the inspector to ensure that the condition would be fully met.

Inspection reports provided by Local Authorities in Scotland and Wales were analysed to identify any concerns noted by inspectors.

EXHIBITION OR EXPLOITATION?

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KEY FINDINGS How many wild animals were permitted to be kept or trained for exhibition or performance during the study time period?

Wild animals were included on the LAIA Regulations 2018 exhibition licences of 431 operators in England, and on the performing animals registrations of 46 operators in Scotland and 56 operators in Wales during the study time period. The licences and registrations included a vast number and diversity of wild vertebrate animals, particularly reptiles, birds and mammals (Table 1). This is highly concerning as these animals are not domesticated; they suffer many health and welfare problems in captive environments; and they are faced with further challenges when used in exhibition settings.

Table 1: The number of wild animals permitted to be kept or trained for exhibition in England by operators licenced under the LAIA Regulations 2018 between 1st October 2018 - 31st October 2020, and the number of wild vertebrate animals registered under the Performing Animals (Regulation) Act 1925 in Scotland and Wales between 1st January 2000 and 31st October 2020.

Mammals

Birds

Reptiles

Amphibians

Fish

Total

2,246

3,225

3,951

1,772

281

11,475

Scotland*

116

198

104

12

0

430

Wales*

54

482

258

13

0

807

England

*Numbers of animals reported for Scotland and Wales likely provide a significant underestimate of the actual number of wild animals kept or trained for exhibition or performance. The number of animals was often unknown so conservative data correction was required for a high proportion of species or species group listings in performing animals registers (52.6% in Scotland; 32.4% in Wales); and, unlike the LAIA Regulations 2018, there is no clear definition of in-scope activities in the Performing Animals (Regulation) Act 1925.

Invertebrates are not included within scope of the LAIA Regulations 2018 or the Performing Animals (Regulation) Act 1925. However, information about the invertebrates kept or trained for exhibition or performance by licensed or registered operators was often provided. We found 6,124 invertebrates were reported to be kept or trained for exhibition by licensed operators in England; 51 by registrants in Scotland; and 115 by registrants in Wales.

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What types of wild animal performances were provided by licensed or registered operators?

The types of wild animal performances provided by operators, and the number of operators providing these performances in England, Scotland and Wales, are summarised in Table 2.

Table 2: Types of animal performances provided by operators licensed to keep or train animals for exhibition under the LAIA Regulations 2018 between 1st October 2018 and 31st October 2020, and by operators registered under the Performing Animals (Regulation) Act 1925 in Scotland and Wales between 1st January 2000 and 31st October 2020.

Number of operators providing each performance type in England, Scotland, Wales and Great Britain Type of performance

England

Scotland

Wales

Great Britain (total for England, Scotland and Wales)

Advertisements

28

0

1

29

Animal-assisted therapy

24

2

3

29

Animal encounters

345

33

35

413

Bird flying shows

84

21

9

114

Circus shows

2

1

1

4

Exhibition at external events

75

8

6

89

Exhibition on site

47

3

0

50

Falconry

27

6

3

36

Falconry training courses

24

3

1

28

Film

93

6

5

104

Magic shows

1

0

0

1

Music videos

8

0

0

8

Photo shoots

106

6

6

118

Radio

3

0

0

3

Social media

59

3

1

63

Theatre

23

0

4

27

TV

94

3

7

104

Unknown

34

10

12

56

Animal encounters (which involve display of wild animals to an audience in-person, with handling of the animals by members of the public) represented by far the most common type of performance provided by operators, with over 77% of operators in Great Britain (413 of 533 operators) providing this type of performance. This is of great concern. Handling of wild animals, particularly by untrained, unfamiliar people, is not in the animals’ best interests and may induce anxiety and stress.12-17 We found that animal encounters were being offered in a wide range of settings, including: nurseries; schools; play groups; play schemes; children’s clubs; children and adult special educational needs groups; summer camps; youth clubs; care homes; day centres; hospitals; children’s and adult’s birthday parties; stag and hen parties; weddings; christenings; adult’s clubs; one to one phobia and familiarisation sessions; petting zoos; charity events; corporate events; community events, including large scale events such as festivals, seasonal events and fairs, as well as events held at libraries, museums and garden centres; education centres and colleges (as part of animal management or care courses); and private training courses (not affiliated with an educational body). Static bird of prey displays which involved public handling of birds were also included in this

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category. Animal encounters with birds of prey sometimes involved members of the public flying, as well as handling, birds.

We found that exhibition at external events (which involves display of wild animals to an audience in-person at off-site events, without public handling) also took place in a wide range of settings, including: nurseries; schools; play groups; play schemes; children’s clubs; children and adult special educational needs groups; summer camps; youth clubs; care homes; hospitals; hospices; private parties, including for children; weddings; christenings; adult’s clubs; charity events; corporate events; and community events, including large scale events such as festivals, seasonal events and fairs, as well as events held at libraries, museums and garden centres.

Static bird of prey displays at external events where the operator stated that public handling was not permitted, or public handling was not advertised or shown in photographs of the events, were included in this category, as were drawing classes at external locations for children and adults. Some operators provided talks, alongside the animals displays.

The display of wild animals in this wide range of settings has significant welfare implications, with animals being frequently exposed to unfamiliar, unnatural and unsuitable environments.

Exhibition of wild animals on site (which involves display of wild animals to an audience in-person on the site where the animal is housed, without public handling) was being provided by operators at animal sanctuaries or rescue centres; art classes; bird of prey centres; castles; children’s holiday clubs; education centres; farms; farm parks; parks; pet shops; and zoos.

How long did performances last and how often were animals required to perform?

Duration of performances The shortest duration of performance was reported for 249 operators ranged between two minutes and nine hours (mean: 1.26 hours). The two minute performance was wedding ring delivery by a bird of prey, while the nine hour performance was exhibition of animals on site at an adventure park.

The longest duration of performance reported for 308 operators ranged between four minutes and 12 hours (mean 2.87 hours). The four minute performance was a dance routine with snakes; the 12 hour performance was exhibition of birds of prey for charity, weddings and other events.

Frequency of performances The maximum number of performances was reported for 200 operators, and ranged between one and ten performances per day (mean: 2.43 performances per day).

Information regarding the number of performances per week, month or year was only available for 39 operators and ranged between 7 days per week to “occasional” or seasonal, e.g. Santa grotto opening times.

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What were the main issues identified by inspectors?

England Of the 350 operators whose inspection reports were analysed to determine whether licence conditions were met in full at the time of inspection, 103 (29.4%) were found to have met all licensing conditions and 247 (70.6%) were found to not be meeting all licensing conditions in full. The licence conditions not met in full by these operators at the time of inspection are shown in Table 3.

Table 3: Licence conditions11 not met in full at the time of inspection by operators applying for a licence to keep or train animals for exhibition in England under the LAIA Regulations 2018 between 1st October 2018 and 31st October 2020.

Number of operators not meeting condition (out of 350 operators with inspection report)

Percentage of operators not meeting condition

2.0 Records

37

10.6

3.0 Use, number and type of animals

11

3.1

4.0 Staffing

81

23.1

5.0 Suitable environment

98

28.0

6.0 Suitable diet

49

14.0

7.0 Monitoring of behaviour and training of animals

38

10.9

Licence condition11

General conditions

8.0 Animal handling and interactions

26

7.4

9.0 Protection from pain, suffering, injury and disease

137

39.1

10.0 Emergencies

97

27.7

Specific conditions 1.0 Insurance

20

5.7

2.0 Emergencies

77

22.0

3.0 Suitable environment

12

3.4

4.0 Monitoring behaviour and training

4

1.1

5.0 Housing with, or apart from, other animals

9

2.6

6.0 Records

39

11.1

7.0 Protection from pain, suffering, injury and disease

129

36.9

Of the three general licensing conditions which were most commonly not met in full at the time of inspection (9.0, 5.0 and 10.0), the parts of each of these conditions which were most commonly not met were: • 9.1 Written procedures must— (a) be in place and implemented covering— (i) feeding regimes, (ii) cleaning regimes, (iii) transportation, (iv) the prevention of, and control of the spread of, disease, (v) monitoring and ensuring the health and welfare of all the animals, (vi) the death or escape of an animal (including the storage of carcasses); (b) be in place covering the care of the animals following the suspension or revocation of the licence or during and following an emergency; • 5.2 Animals must be kept at all times in an environment suitable to their species and condition (including health status and age) with respect to— (a) their behavioural needs, (b) its situation, space, air quality, cleanliness and temperature, (c) the water quality (where relevant), (d) noise levels, (e) light levels, (f) ventilation; and • 10.1 A written emergency plan, acceptable to the Local Authority, must be in place, known and available to all staff on the premises used for the licensable activity, and followed where necessary to ensure appropriate steps are taken to protect all the people and animals on the premises in case of fire or in case of breakdowns for essential heating, ventilation and aeration or filtration systems or other emergencies.11

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Of the three specific licence conditions that were most commonly not met in full at the time of inspection (7.0, 2.0 and 6.0), the parts of each of these conditions which were most commonly not met were: • 7.1 A register must be kept of each animal exhibited or to be exhibited which must include— (a) the full name of the supplier of the animal, (b) its date of birth, (c) the date of its arrival, (d) its name (if any), age, sex, neuter status, description and microchip or ring number (if applicable), (e) the name and contact details of the animal’s normal veterinarian and details of any insurance relating to it, (f) details of the animal’s relevant medical and behavioural history including details of any treatment administered against parasites and any restrictions on exercise or diet, (g) a record of the date or dates of the animal’s most recent vaccination, worming and flea treatments, and (h) the distance to and times taken for it to travel to and from each exhibition event; • 2.1 A written policy detailing contingency measures in the event of the breakdown of a vehicle used to transport the animals or any other emergency must be available to all staff; and • 6.1 The licence holder must keep a list of each animal kept, or trained, for exhibition with all the information necessary to identify that animal individually (including its common and scientific names) and must provide the Local Authority with a copy of the list and any change to it as soon as practicable after the change.11 Scotland Local Authorities in Scotland provided six inspection reports for operators exhibiting or training wild animals for performance. Three of the inspection reports analysed highlighted no concerns. No concerns were highlighted by the inspector in the fourth report, however we noted that the aviary size was small, measuring only approximately 2.5-3 x wingspan for length, width and height. In the fifth report, the inspector highlighted concerns about the enclosure sizes of multiple mammal and reptile species, as well as lack of a hide area and legal import paperwork for a bird of prey. Concerns were also raised about overheating of certain animals in transport and predator and prey animals being transported in the same vehicle. The sixth report highlighted that the operator needed to obtain fire detection and firefighting equipment.

Wales Local Authorities in Wales provided five inspection reports for operators exhibiting or training wild animals for performance. Concerns were highlighted by inspectors in four of these reports. Two inspection reports highlighted that reindeer could pose a potential safety risk to the public if exhibited; and advice was given regarding increasing the hard standing in the enclosure in one report. A third inspection report highlighted concerns about the size and cleanliness of aviaries, and lack of a water source in one aviary. The fourth inspection report highlighted that animal records were not kept and advised that records of each animal and exhibits travelled to must be kept.

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SPOTLIGHT ON SPECIES AND ANIMAL GROUPS OF CONCERN WHAT ARE THE KEY ISSUES WITH KEEPING OR TRAINING THESE ANIMALS FOR EXHIBITION OR PERFORMANCE? REINDEER

© Charles Hackley, flickr cc

• Reindeer were previously imported to the UK from Norway, Sweden and Finland until import restrictions were put in place in 2016 and 2018 due to the risk of introducing chronic wasting disease.18 Reindeer have also been bred within the UK in recent years, for commercial use, particularly over the Christmas period.19 We found 511 reindeer included on exhibition licences in England, and 86 on performing animal registers in Scotland and Wales.

• Captive keeping, particularly for exhibition purposes, is fraught with health and welfare concerns.19 These are gregarious, herdforming, wide-ranging animals with a complex wild diet.19 In captivity, reindeer are often: - Kept or exhibited in inappropriate social groups.20 Ten out of 38 operators licensed to exhibit reindeer in England, and two out of three operators registered to exhibit reindeer in Scotland listed just two reindeer on their licence or register; - Confined to restricted environments for exhibition purposes. Many photos on operator websites showed reindeer exhibited in a small pen at events, often restrained by head collar and lead rope; - Fed an inappropriate captive diet, frequently resulting in weight loss and poor body condition.19 We found descriptions of reindeer diets in inspection reports where inappropriate food items (e.g. straw) were included in the diet, and recommended dietary components (e.g. browse and/or reindeer pellets) were not mentioned;19 - Exposed to handling by members of the public. Animal encounters were commonly provided by operators licensed or registered to exhibit reindeer in Great Britain (30 out of 45 operators). We found many photos on operator websites of reindeer being stroked or kissed by members of the public when exhibited. We saw video footage of a reindeer being repeatedly restrained for this purpose, despite attempts to pull away. For reindeer exhibited in a small pen, often the only opportunity to avoid public handling is to stay in the centre of the pen.

- Exposed to crowded, unnatural environments, including at busy Christmas events, as well as other corporate, community and private events. Several operators also offered reindeer-led sleigh rides, carrying one or more passengers through crowded streets.

- Transported long distances. Several operator websites stated that they would travel anywhere in the UK to exhibit reindeer. Another operator provided reindeer for off-site exhibition, away from their home environment, for six to eight weeks at a time.

MEERKATS • Meerkats are commonly kept or trained for exhibition or performance. We found 133 meerkats included on exhibition licences in England, and 15 on performing animals registers in Scotland and Wales.

• These gregarious, desert-adapted mongooses, which live in stable social groups of six to 40 animals in southern Africa, suffer from many welfare problems in captivity. Meerkats in captivity are: - Often kept in inappropriate social groups. Of the 32 operators which included the number of meerkats on their exhibition licence, two operators had a single meerkat and nine had only two meerkats on their licence; - Prone to developing behavioural problems, including pacing, head bobbing, over-grooming and selfmutilation if kept alone or in inappropriate social groups;21

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- Frequently diagnosed with captivity-associated nutritional disorders, specifically hypercholesteroleamia (high blood cholesterol) and meningeal cholesterol granuloma formation (accumulations of cholesterol around the brain);22 - Frequently exposed to handling by members of the public when exhibited. Almost all operators which included meerkats on their exhibition licence or performing animals register entry provided animal encounters (38 of 40 operators), in a wide range of settings including: at schools; holiday camps; school clubs; nursing and care homes; private events; charity events; corporate events; and community events.

AFRICAN PYGMY HEDGEHOGS • African pygmy hedgehogs are commonly kept or trained for exhibition or performance: 105 were included on exhibition licences in England, and 21 on performing animals registers in Scotland and Wales.

• It is not possible to provide for their complex welfare needs in captivity. African pygmy hedgehogs are nocturnal animals that inhabit savanna and grassy areas in Africa, consuming a variety of invertebrate and vertebrate prey, carrion, and plant material.23,24 • African pygmy hedgehogs suffer from many health problems in captivity, most commonly skin, gastrointestinal and skeletal diseases, and infestation with parasitic worms (ascariasis) is emerging as a disease associated with their captivity.25,26 They can also carry and transmit numerous zoonotic diseases to people that come into contact with them.27 • Instances of inadequate enclosure size, neglect, inappropriate diet and deliberate abandonment have been reported.28 • African pygmy hedgehogs are exhibited in a wide variety of unnatural environments, from children’s parties to village shows, and are commonly exposed to handling by members of the public: 69 out of 75 operators which included African pygmy hedgehogs on their exhibition licence or performing animals registration provided animal encounters.

LARGE WILD MAMMALS • We found that a wide variety of large wild mammals were being kept or trained for exhibition under LAIA Regulations licence in England, including 12 zebra, 10 lions, 10 tigers, 10 wolves, six leopards, two ligers, two giraffe, and two pygmy hippopotamuses. These animals were being kept by four licensed operators.

• In their wild environment, these social animals have large home ranges and are adapted to complex environments. Some also establish complex social groupings and behaviours.

• In England, four of the 12 zebra included on LAIA Regulations licences were being used by two operators for circus performances, although this activity had either ceased or was due to be reviewed by the local Licensing Authority since a prohibition on the use of wild animals in travelling circuses in England came into force in 2020.1 • The other large wild mammals listed were being kept and trained for animal encounters, TV, film, photo shoots and advertisements. Many of these animals had previously been kept and trained for exhibition in a circus. It is of great concern that, despite the prohibition on the use of wild animals in travelling circuses on ethical grounds, these animals continue to be used for unnatural performances simply to entertain the public, promoting the perception of wild animals as an entertainment commodity, under a LAIA Regulations 2018 licence. The LAIA Regulations 2018 do nothing to prevent these animals being regularly transported and kept in temporary accommodation for exhibition purposes, as would be the case with a travelling circus.

This 'loophole' serves to undermine the ban on wild animals in travelling circuses, and must be addressed.

PRIMATES • We found that a large number of primates were included on exhibition licences in England (75 animals).

• These highly-intelligent, social animals are adapted to life in complex, wild environments and suffer with many health and welfare problems in captivity.29 • Two exhibition licences included a single marmoset, indicating that these highly-social animals were either being kept alone, or being removed from their social group to be exhibited alone, both of which would result in significant stress and compromised welfare.

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• Most operators keeping or training primates for exhibition or performance in Great Britain, provided animal encounters (8 of 11 operators). Other types of performance provided were TV; film; social media; photo shoots; advertisements; music videos; theatre; exhibition at external events; and exhibition on site, including permanent display in a shop, despite The Defra Code of Practice for the Welfare of Privately Kept NonHuman Primates stating that enclosures should be located away from busy or noisy areas, in order to reduce stress and interference from passers-by.30 • The new licensing system proposed for pet primates in England in the draft Animal Welfare (Kept Animals) Bill does nothing to prohibit legally kept pet primates being used for exhibition.31 NOCTURNAL MAMMALS • 332 primarily nocturnal mammals (active at night) were included on licences to keep or train animals for exhibition in England (Table 4).

Table 4: Primarily nocturnal wild mammals that were included on licences to keep or train animals for exhibition in England, issued under the LAIA Regulations 2018 between 1st October 2018 and 31st October 2020.

Primarily nocturnal mammal species African pygmy hedgehog

Number of animals included on licences* 105

Crested porcupine

4

Duprasi

38

Egyptian fruit bat

21

European hedgehog

4

Four-toed jerboa

2

Gambian pouched rat

4

Greater hedgehog tenrec

2

Ground cuscus

3

Indian crested porcupine

1

Indian flying fox

2

Kinkajou

5

Lesser hedgehog tenrec

2

Linnaeus’s two-toed sloth

4

Long-eared hedgehog

5

Long-nosed potoroo

1

Lyle’s flying fox

6

Northern flying squirrel

2

Palm civet

1

Raccoon

20

Red fox

9

Striped skunk

22

Sugar glider

44

Virginia opossum

1

Wolf

10

Woodland dormouse

5

* These figures likely underestimate the number of nocturnal mammals included on licences as only mammals known to species level were analysed. For example, a further 42 foxes of unknown species were included on licences, which are likely nocturnal.

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• This is of great concern as most exhibition activities occur during the day, when nocturnal animals would naturally be sleeping.

• Crepuscular mammals (active at dawn and dusk) (including two binturong (a large civet-like animal native to parts of Asia), five grey squirrels, and 30 jerboa (long-tailed rodents native to the deserts and steppes of eastern Europe, Asia, and northern Africa) of unknown species which are likely crepuscular or nocturnal) and animals that are nocturnal, extending into crepuscular, depending on the time of year (e.g. one mouse-like hamster) were also included on licences. Exhibition activities are likely to be held at times when these animals would naturally sleep.

• The exhibition of nocturnal non-mammalian vertebrates is also a significant welfare concern. However, only mammals were analysed here to give an indication of the scale of the problem.

BIRDS OF PREY • More than 2,400 birds of prey were included on exhibition licences in England, and more than 670 on performing animal registers in Scotland and Wales. The species most commonly kept or trained for exhibition or performance were the Harris’s hawk, barn owl, Eurasian eagle-owl, tawny owl and common kestrel.

• Wild birds of prey are long-lived, fly over wide ranges and territories that are generally larger than those for many other wild terrestrial birds, and many hunt live vertebrates.32 • Bred in captivity, they can suffer from numerous captivity-associated health and welfare problems, including respiratory diseases such as aspergillosis, foot health problems such as pododermatitis and behavioural abnormalities.33,34 We found examples of birds of prey kept for exhibition purposes being subjected to: Restricted movement: - Tethering (tying a bird to a perch to restrict its movement) was commonly used to exhibit birds of prey in static displays at events, some of which would last all day. In inspection notes, we also found examples of birds of prey being routinely tethered when not exhibited and when not flown (and some birds were only flown three times per week).

- The LAIA Regulations 2018 exhibition guidance does little to prevent tethering, stating only that birds must not be tethered permanently, and if animals are unable to move fully (e.g., fly) in any temporary enclosure (e.g. whilst being exhibited), they must be given the chance to do so at least once each day and a record kept.11 In zoos, it is recommended that owls, vultures, caracaras, secretary birds and harrier hawks should not be tethered; kites should not be tethered for prolonged periods; and Harris’s hawks, if tethered, should be managed in proximity to the birds that they fly with.35,36 None of these recommendations are included in the LAIA Regulations 2018 exhibition guidance.11 - Not only does tethering restrict natural flight behaviour, there is also a risk of leg fracture.33 This is the most common type of orthopaedic injury in captive birds of prey and is predominantly an injury of newly tethered birds attempting to fly away from the perch.33 - When permitted to fly, in some cases this was just within an aviary; others were permitted to fly at specific times outside under the supervision of their keeper, for exercise, training or exhibition purposes (e.g. bird flying shows, falconry and animal encounters).

- Some aviaries provided were very small, e.g. measuring 2.5 x the wingspan of the birds, and some birds spent considerable periods of time confined to small boxes, e.g. overnight, during travel, and if stressed or fatigued during exhibition.

Hand-rearing and imprinting: - We found examples of birds of prey being hand-reared and imprinted on humans.

- This concerning practice can result in behavioural issues, including aggression and screaming.34 - Other behavioural abnormalities, including feather plucking, chewing and self-mutilation have been reported in captive birds of prey; feather plucking appears to be more commonly reported in the Harris’s hawk, the most commonly-kept bird of prey for exhibition.34 Reducing feeding (“starving”) to encourage desired behaviours: - Captive birds of prey may be kept at a low bodyweight to encourage them to overcome their natural fear of humans and feed from a human hand,37 and at the start of the flying season to encourage them to hunt, e.g. if used for falconry.38 One operator reported reducing weight to “keep the bird keen”. This practice of “starving” before the flying season can result in low blood sugar in trained birds, presenting as collapse after flight.38 15

Long travel times - We found examples of licensed or registered operators that would travel with their birds up to eight hours to an exhibition location, and several reported covering the whole of the UK. • Birds of prey were being kept for exhibition in England, Scotland and Wales for wide-ranging types of performances including: TV; film; social media; photo shoots; advertisements; music videos; theatre; animal encounters; exhibition on site; exhibition at external events; bird flying shows; falconry; falconry training courses; and animal-assisted therapy.

• Although falconry (defined as hunting wild animals in their natural state and habitat by means of a trained bird of prey) is considered to be a sport so it does not fall within the scope of LAIA Regulations 2018 exhibition licensing, we found that birds of prey were being exhibited to members of the public in falconry sessions and falconry training courses by operators with a LAIA Regulations 2018 exhibition licence. The exhibition of captive birds of prey for falconry raises particular ethical concerns. We found that operators were exhibiting captive birds of prey (often alongside ferrets and dogs) hunting wild animals including ducks, rabbits, pheasants and squirrels in the local countryside.

REPTILES • Over 3,590 reptiles were included on exhibition licences in England; and over 360 reptiles were included on performing animal registers in Scotland and Wales. The species most commonly-kept or trained for exhibition or performance were the bearded dragon, boa constrictor, corn snake, leopard gecko and royal python.

• This raises significant welfare concerns. Reptiles are frequently kept in inappropriate conditions in captivity in the UK, resulting in poor health and welfare.39 Nutritional diseases such as nutritional secondary hyperparathyroidism, dysecdysis, follicular stasis (an ovarian disorder) and constipation in lizards; nutritional secondary hyperparathyroidism, renal disease, respiratory disease, stomatitis (inflammation and infection of the mouth), dystocia (retained eggs), follicular stasis and septicaemia in chelonians; dysecdysis, dermatitis (skin inflammation and infection), stomatitis and dystocia in snakes - these are just a handful of examples of the health problems commonly seen in reptiles that are associated with inappropriate husbandry.40-45 • Many captive reptiles suffer neglect, are abandoned, or are found as strays; the RSPCA reported that it rescued more than 500 snakes, more than 300 turtles, and 145 bearded dragons in 2018 alone.46 • We found evidence of operators not providing UV-B radiation (UV-B provision is essential for reptile health) for reptiles; keeping reptiles in very small enclosures; and not monitoring temperature and UV light levels in enclosures.

• Many large species of snake were included on exhibition licences and in performing animal registers. These snakes are frequently kept in enclosures that do not permit them to fully stretch out, let alone express normal movement and activity patterns.16 • Operators were providing reptiles for wide-ranging performances, including: TV; film; radio; music videos; theatre; social media; photo shoots; advertisements; exhibition at external events; exhibition on site; animal encounters; and animal-assisted therapy; in a wide range of settings from schools to community events.

• The handling of reptiles by members of the public in these settings is particularly concerning, as recent research has indicated that even gentle handling of bearded dragons may increase anxiety in these animals.13 There is no convincing evidence that reptiles enjoy human presence or contact and an acute stress response to handling has been demonstrated in some species, such as gopher tortoises.14,15 Cloacal evacuations (emptying of the bowels) when reptiles are handled are also suggestive of fear/stress.16 • Public handling of reptiles also presents health and safety concerns. We found many photos of large snakes being draped around children and adults’ necks on operator websites and social media, with associated risk of injury. Members of the public handling reptiles are particularly at risk of zoonotic disease caused by Salmonella spp. (see later section on ‘Animals that pose a significant zoonotic disease risk’).

• Equally concerning is that these animals may be spending considerable periods of time out of their controlled home environment for exhibition purposes. Reptiles are ectotherms (cold blooded animals) which require specific temperature, light (particularly UV-B radiation) and humidity levels in order to function normally. Time spent outside of an optimally controlled environment can have detrimental effects on their health and welfare.

The longest reported time period for reptiles being at an off-site location for exhibition was 10 hours.

EXHIBITION OR EXPLOITATION?

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AMPHIBIANS • More than 1,770 amphibians were included on exhibition licences in England; and 25 amphibians were included on performing animal registers in Scotland and Wales. The most commonly-represented species were the axolotl (a type of salamander), White’s tree frog, African bullfrog, South American horned frog, and cane toad.

• We found that most licensed or registered operators (128 of 139 operators) were providing animal encounters, involving handling by members of the public, in a wide variety of settings including children’s parties and clubs, adult clubs, team-building experiences, nurseries, schools, care homes, and public events.

Handling can have several deleterious effects: - White’s tree frogs (a species that is exhibited in large numbers) were found to show decreased activity levels over time when exposed to handling and other stressors.17 - Amphibians have delicate skin, the integrity of which is key for osmoregulation (water balance) and respiration in some species, making them unsuited to regular handling.47 - Members of the public handling amphibians are at risk of zoonotic disease (particularly caused by Salmonella spp. and Mycobacteria spp.) and exposure to potentially toxic compounds in amphibian skin secretions.48-49 - In circumstances where amphibians must be handled (e.g. for health checks), it is recommended that adult frogs and toads and salamanders are handled with moistened powder-free nitrile gloves to reduce the risk of trauma to delicate amphibian skin, zoonotic pathogen transfer, and potential exposure to toxic compounds.49-51 • No reference to these handling concerns is made in the LAIA Regulations 2018 exhibition guidance.

• As with reptiles, it is also concerning that amphibians may be spending considerable periods of time out of their controlled home environment for exhibition purposes. Amphibians are ectotherms which require specific temperature, light (particularly UV-B radiation) and humidity levels in order to function normally. Time spent outside of an optimally controlled environment can have detrimental effects on their health and welfare. We found that some amphibians were being exhibited at all day events at an off-site location.

INVERTEBRATES • Invertebrates are afforded no welfare protection under the LAIA Regulations 2018 or Performing Animals (Regulation) Act 1925 as only vertebrate animals are included within scope of the legislation.

• We found that more than 6,100 invertebrates in England, and more than 160 invertebrates in Scotland and Wales, were being kept or trained for exhibition or performance by licensed or registered operators.

• A vast diversity of species were represented, the most common being the Madagascar hissing cockroach, giant African land snail, sun beetle, black beauty stick insect and giant African millipede.

• All invertebrates have needs which must be met if they are to have good welfare in a captive environment; however, this is not currently reflected in current legislation in England, Scotland and Wales. Recent research and policy debate has also highlighted the need to recognise certain invertebrates, notably decapod crustaceans and cephalopods, as sentient animals in legislation.52 At the time of writing the UK Government was considering including decapod crustaceans and cephalopods as sentient beings in the Animal Welfare (Sentience) Bill.53,54 • We found that invertebrates were being provided by operators in a wide variety of exhibition settings, including: TV; film; social media; radio; music videos; theatre; advertisements; photo shoots; exhibition at external events; exhibition on site; animal encounters; and animal-assisted therapy.

• The large number of invertebrates used for exhibition, and unnatural, and likely aversive, exhibition conditions to which they are exposed, highlights the need to recognise invertebrates as animals which require welfare protection under British law.

• Environmental risks associated with exhibiting invertebrates must also be addressed. The use of non-native invertebrates, including the use of invasive crayfish without a licence, in the TV programme ‘I’m a Celebrity …

Get Me Out of Here!’ in Wales in 2020, highlighted concerns about the possibilty of animals escaping and posing a risk to native wildlife.55,56

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INVASIVE ALIEN SPECIES • In England and Wales, 30 species of animal that are included on a list of invasive non-native (alien) animal species of concern to the EU because of their invasiveness and ability to establish, must not be used in shows or exhibitions that allow members of the public to interact with these animals.57 • We found that 62 animals of invasive alien species of concern were included on LAIA Regulations 2018 exhibition licences issued in England between 1st October 2018 and 31st October 2020 (Table 5). Of the 25 operators keeping these animals, 22 provide animal encounters. If these operators are using any of these animals for animal encounters, they are likely committing an offence.57 Table 5: Number of animals of invasive non-native (alien) species of concern licenced to be kept or trained for exhibition under the LAIA Regulations 2018 between 1st October 2018 and 31st October 2020.

Species

Number of animals

Raccoon

20

Raccoon dog

12

Coati

9

Grey squirrel

5

Siberian chipmunk

5

Red-eared slider

4

Yellow-bellied slider

4

Muntjac deer

2

Sacred ibis

1

ANIMALS THAT POSE A SIGNIFICANT ZOONOTIC DISEASE RISK • Any individuals that come into close contact with exhibited or performing wild animals carrying zoonotic pathogens are at risk of zoonotic disease (disease transmitted from animals to humans).

• Animal encounters (which are provided by over 77% of operators keeping or training wild animals for exhibition or performance in Great Britain) pose a particularly high zoonotic disease risk due to the close contact between animals and people, increasing the risk of transmission of pathogens present in animal body fluids, secretions, excretions, lesions and on inanimate objects.

• While the LAIA Regulations 2018 exhibition guidance states that clients handling animals must be supervised at all times and offered facilities to wash their hands before and afterwards, this does not eliminate the risk of zoonotic pathogen transfer.11 Wild animals used for exhibition or performance in Great Britain that pose a significant zoonotic disease risk include: • Ungulates, primates and bats: - A quarter of mammals in wildlife trade host 75% of known zoonotic viruses.58 Even-toed ungulates, primates, and bats are the major zoonotic reservoirs in wildlife trade.58 - There were 647 even-toed ungulates, 75 primates and 30 bats included on LAIA Regulations 2018 licences in England between 1st October 2018 and 31st October 2020; and 86 even-toed ungulates registered under the Performing Animals (Regulation) Act 1925 in Scotland and Wales between 1st January 2000 and 31st October 2020.

• Psittacine birds: - Psittacine birds (e.g. parrots, parakeets, cockatiels), alongside pigeons, doves and poultry, represent the highest risk to humans of Chlamydia psittaci (C. psittaci) infection.59,60 - A retrospective analysis of C. psittaci antibody tests from psittacine birds presented to a veterinary practice in London indicated that there is widespread dissemination of C. psittaci in the pet parrot population in southern England.61 - C. psittaci is the causative agent of psittacosis (or ornithosis) in humans, an acute respiratory disease characterised by flu-like symptoms (fever, headache, muscle aches), but which can also progress to

EXHIBITION OR EXPLOITATION?

18

severe pneumonia and non-respiratory health problems.60 Elderly or immunocompromised individuals are at greatest risk of severe disease.60 Between 25 and 50 cases of psittacosis are laboratory confirmed in England and Wales each year.62 These figures are likely just the ‘tip of the iceberg’ as psittacosis may be mistaken for a cold or flu, and usually only severely ill patients are tested for C. psittaci.63 - There were 339 psittacine birds included on LAIA Regulations 2018 licences in England between 1st October 2018 and 31st October 2020.

- We found that many operators providing animal encounters were doing so in care homes for the elderly.

• Reptiles: - Salmonella spp. are asymptomatically carried by most, if not all, reptiles in their gut.40,64 Shedding in faeces is intermittent, however close contact between reptiles and members of the public handling these animals puts them at risk of infection.40 - Babies, children under five years old, pregnant women, the elderly and immunocompromised are highest risk groups.64 We found that many operators providing animal encounters were doing so in settings with young children (e.g. nurseries and schools) and care homes for the elderly.

- Concerningly, Salmonella spp. carried by pet reptiles can be multi-drug resistant; one study in Spain detected Salmonella spp. carriage in 48% of the pet reptiles examined from households and pet shops, 72% of which were multidrug-resistant strains.65

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WHY IS CURRENT LEGISLATION NOT PROTECTING THESE ANIMALS? It is clear from our investigation that a vast number and diversity of wild animals are legally being kept or trained for exhibition or performance in Great Britain. These non-domesticated animals, adapted to life in complex wild environments, are frequently housed in unsuitable conditions, handled by unfamiliar people, and exposed to unfamiliar and unnatural environments in the course of their exhibition. These practices pose a high risk to the health and welfare of the animals involved. So why is this being allowed to happen under current legislation in Great Britain?

1. Deficiencies of the Performing Animals (Regulation) Act 1925 In Scotland and Wales, operators need only register with their Local Authority in order to exhibit or train performing wild animals under the Performing Animals (Regulation) Act 1925.8 This is a one-off registration and no inspection process is required.8 Any vertebrate animal may be registered, and the registration can only be prohibited or restricted where it is proved to the satisfaction of a court on a complaint by a constable or Local Authority officer that the training or exhibition of any performing animal has been ‘accompanied by cruelty’, although what constitutes ‘cruelty’ is not defined within the Act.8 The legislation does not include a definition for performing animals or exhibition, nor does it include examples of in-scope activities; these are significant omissions, resulting in many operators not being covered by the legislation.

The lack of a requirement for an inspection process in legislation is clearly problematic, and many Local Authorities choose to inspect premises regardless. Fifteen Local Authorities in Scotland and ten Local Authorities in Wales reported that they would carry out an inspection when an application is made under the Performing Animals (Regulation) Act 1925. A further two Local Authorities in Scotland, and three in Wales, reported that the decision to carry out an inspection depended on information included in the application, and one Local Authority in Scotland reported that inspections are carried out but not routinely. Three Local Authorities in Scotland, and five Local Authorities in Wales, reported that they do not carry out an inspection when an application is made under the Performing Animals (Regulation) Act 1925. A further two Local Authorities in Scotland reported that no applications had been received so they either did not have a policy on the matter or did not carry out inspections.

Seventeen of the 18 Local Authorities in Scotland, and 12 of the 13 Local Authorities in Wales, which reported that they either carry out inspections, or may depending on the circumstances, provided us with information regarding inspectors used. Inspectors would either be Local Authority officers (16 Local Authorities) or vets (three Local Authorities), or a combination of Local Authority officers and vets (10 Local Authorities).

These findings, coupled with the identification of multiple animal welfare and other issues on the inspection reports provided to us by Local Authorities in Scotland and Wales, demonstrate a clear need for a mandatory inspection process for operators exhibiting animals in Scotland and Wales.

The Welsh government held a consultation in 2020 on proposals to replace the Performing Animals (Regulation) Act 1925 with legislation similar to the LAIA Regulations 2018 in England and, in 2021, the Welsh government committed to developing a national model for regulation of animal welfare which would introduce registration for animal exhibits, amongst other measures.66,67 There appears to be no immediate plan to replace the Performing Animals (Regulation) Act 1925 in Scotland, although consideration of the issue is on the workplan for Scotland's Animal Welfare Commission in the longer term.68 2. Deficiencies of the LAIA Regulations 2018 From 1st October 2018, the LAIA Regulations 2018 replaced the Performing Animals (Regulation) Act 1925 in England.7 The LAIA Regulations 2018 are a significant improvement on the Performing Animals (Regulation) Act 1925, providing a clear definition of in-scope and out-of-scope activities, guidance notes for Local Authorities on the keeping and training of animals for exhibition in the form of licence conditions, and requiring an inspection to be undertaken prior to the granting of a licence and prior to licence renewal (every 3 years).11 However, our assessment of the legislation and inspection reports provided by Local Authorities in England highlighted a number of serious concerns in relation to wild animals: Specialist knowledge of operators: • Wild animals have complex needs which are challenging to meet in captive environments. However, there is no requirement for keepers or trainers of wild animals for exhibition licensed under the LAIA Regulations 2018 to have qualifications and formal training in the health and welfare of the animals for which they are licensed.

EXHIBITION OR EXPLOITATION?

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• General licence condition 4.1 requires that sufficient numbers of people who are competent for the purpose must be available to provide a level of care that ensures that the welfare needs of all the animals are met; and general licence condition 4.2 requires that the licence holder, or a designated manager, and any staff employed to care for the animals must have competence to identify the normal behaviour of the species for which they are caring, and to recognise signs of, and take appropriate measures to mitigate or prevent, pain, suffering, injury, disease or abnormal behaviour.11 • For more than 50 operators, we found that experience of keeping animals (and experience of selling or exhibiting animals in some cases) and/or membership of an animal keeping society, was cited in the explanatory notes as evidence for licence conditions 4.1 and 4.2 being met, without any reference to formal training or qualifications. Relying on experience alone can result in the perpetuation of poor welfare practices if these practices are not recognised and corrected. This is a real concern for captive wild animals, as health and welfare problems due to inappropriate husbandry are very common.69 Using social media groups; working as a receptionist at a veterinary practice; a training course undertaken over 25 years prior to the inspection; and experience in conservation work (with no mention of animal welfare) were also cited in inspection reports to evidence competence for these licence conditions.

• General licence condition 4.3 requires that the licence holder must provide and ensure the implementation of a written training policy for all staff.11 Again, there is no requirement for this training to include qualifications or formal training in the welfare, behaviour, or health of the species being kept. The training must involve ‘use of online courses and literature’, the quality of which is highly variable for captive wild animals.11,70 We found that some inspectors marked general licence condition 4.3 as not applicable if the operator had no staff, despite the supporting guidance stating that if no staff are employed, the licence holder must demonstrate their own knowledge development.11 In-house training of staff was also cited as evidence of compliance with general licence condition 4.3, however in-house training of staff by operators who are not required to have qualifications and formal training in the health, welfare and handling of the animals for which they are licensed, risks perpetuating poor welfare practices.

Specialist knowledge of inspectors: • The LAIA Regulations do not require inspectors to have specialist knowledge of the welfare needs of the vast array of wild animal species that are kept or trained for exhibition.

• All inspectors must be suitably qualified to carry out inspections.71 This is defined as: (a) Any person holding a Level 3 certificate or equivalent granted by a body, recognised and regulated by the Office of Qualifications and Examinations Regulation which oversees the training and assessment of persons in inspecting and licensing animal activities businesses, confirming the passing of an independent examination. A person is only considered to be qualified to inspect a particular type of activity if their certificate applies to that activity; or (b) Any person holding a formal veterinary qualification, as recognised by the Royal College of Veterinary Surgeons (“RCVS”), together with a relevant RCVS continuing professional development record; or (c) Until October 2021, any person that can show evidence of at least one year of experience in licensing and inspecting animal activities businesses; or (d) From 1 October 2021, any person that can show evidence of at least one year of experience in licencing and inspecting animal activities businesses and, by 1 October 2021, is enrolled on a course leading to a Level 3 certificate qualification referenced in paragraph 16(a) above with the course having to be completed by 1 October 2022.71 • None of these requirements take into account the specialist knowledge that is required to assess whether the complex needs of the many different wild animals being kept or trained for exhibition are being met.

Given the wide variety of wild animals being kept or trained for exhibition by operators in England under a LAIA Regulations 2018 licence, and the varied and complex needs of wild animals in captivity, it is unlikely that Local Authority inspectors have welfare expertise across the range of wild animals exhibited.

• Our review of inspector notes in the inspection reports provided, revealed examples of where inspectors may have unknowingly permitted poor welfare practices to continue. For example, inappropriate reindeer diets were deemed to be acceptable by inspectors, including feeding straw; grazing on a grass paddock; and no mention of browse in the diet.18 In one report, a marmoset diet was described yet there was no mention of oral vitamin D3 supplementation, gut-loading invertebrates with calcium, or providing marmoset gum, all of which are recommended for these primates.72,73 In one report, an inspector stated that all vivariums for reptiles were completely enclosed, preventing any risk of zoonotic transmission. However, this would not prevent zoonotic agents such as Salmonella spp. passing from reptiles to staff when they handle reptiles, their enclosure, enclosure furniture or raw reptile feed.64 One inspector advised regular worming of a species, referencing Google, when regular faecal parasite testing is the current recommended practice for the species.19 The rearing technique for birds of prey was rarely commented upon, however both handrearing and imprinting were mentioned, with no notes about the risk of behavioural problems associated with these practices.34 One inspector accepted that a parrot had its wing clipped, with no mention of the negative welfare implications of this, including removing the bird’s ability to express normal behaviour;

21

increased risk of feather plucking; risk of development of learned fear and anxiety disorders; and risk of trauma due to lack of balance or loss of gliding ability.74 In one report, it was deemed acceptable for animals to be left in a vehicle for up to an hour. Another inspector reported that an operator occasionally killed rodents by blunt trauma to the head to tempt reptiles to feed; however, the inspector notes did not provide evidence that the operator was competent in this slaughter method, nor that the good welfare of these animals was assured prior to death.

Detailed, evidence-based, species-specific guidance: • The LAIA Regulations 2018 exhibition guidance for Local Authorities lacks detailed, evidence-based, species-specific guidance regarding a suitable environment for captive wild animals.11 • Inspectors found that 98 operators did not meet general licence condition 5.0 for a suitable environment, however it is also likely that other unsuitable environments were missed, given the complex needs of wild animals, the wide variety of species kept, and the lack of a requirement for inspectors to demonstrate Continued Professional Development in captive wild animal welfare.

• Detailed species-specific guidance, for example, recommended temperature and UV-B gradients for exhibited reptile species, recommended diets, and recommended enclosure sizes for exhibited wild animal species, and equipping all inspectors with the appropriate equipment to test parameters on site (e.g. an infrared thermometer and UV Index meter) may reduce the likelihood of inappropriate environmental conditions being overlooked.

Defined limits on travel times, exhibition times, types of performance that may be undertaken for each species, and clear guidance on conditions required during performance and at the performance site: • Defined limits on travel and exhibition times are not currently included in the LAIA Regulations 2018 exhibition guidance.11 We found that multiple licensed operators offered to travel anywhere in the UK to exhibit their animals, and travel time of up to 8 hours was reported by one operator. Exhibition times were highly variable, ranging between two minutes and 12 hours, with some animals being offered off-site for 6-8 weeks at a time.

• The LAIA Regulations 2018 exhibition guidance does not stipulate which types of performance may be undertaken by which species.11 We found that animal encounters, involving handling by members of the public, were provided by the majority (80%; 345 of 431 operators) of operators licensed under the LAIA Regulations 2018. However, handling of wild animals may induce stress and anxiety,12-17 and handling of these non-domesticated animals by untrained, unfamiliar people is of particular concern.

• Much of the focus of the LAIA Regulations 2018 exhibition guidance is on the living conditions of animals at their home site, rather than where they are being used for exhibition (if this is away from their home site).11 The guidance states that ‘suitable temporary accommodation’ must be provided for all the animals at any venue where they are exhibited, and that all animals involved for longer than a day must be provided with onsite housing and/or rest areas as set out under Condition 5.2 that allow for a range of movement and natural behaviours.11 As most performances last less than a day, there is minimal guidance on how animals should be kept at the performance site in the vast majority of cases. Furthermore, there is no requirement for inspections to take place at the performance site or during performances - inspections take place at the home site of the animals.

Frequency of inspections: • Under the LAIA Regulations 2018, inspections are only required prior to granting and renewal of a licence (which is every three years), although in the case of complaints or other information that suggests licence conditions are not being complied with or that the welfare of the animals involved in a licensed activity is at risk, unannounced inspections should also be carried out.71 • This is concerning as many welfare issues could arise over a three-year period. For comparison, hiring out horses requires an annual inspection under the LAIA Regulations 2018, and licensed zoos are inspected annually under the Zoo Licensing Act 1981.71,75,76 • The decision to make exhibition licences renewable only once every three years (and thus inspections to take place only once every three years) was made on the basis that these activities were previously only subject to a simple registration system under the Performing Animals (Regulation) Act 1925.71 However, this should not be a reason to limit the requirements under the 2018 regulations, which could have negative consequences for animal welfare.

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RECOMMENDATIONS We call on the UK government, the Scottish Parliament, and the Welsh Parliament to introduce a prohibition on the keeping or training of wild animals for exhibition or performance in legislation.

While the unethical practice of using wild animals in travelling circuses has been widely acknowledged, resulting in the prohibition of their keeping for this purpose in England, Wales and Scotland, it is clear that the use of wild animals for other types of exhibition or performance in Great Britain has not been given sufficient consideration. Kept and trained for exhibition or performance in their many thousands, these vastly diverse animals of numerous species commonly suffer from captivity-associated health and welfare problems, and face further welfare compromise when used in exhibition or performance settings. Often kept in unsuitable environments, they are frequently exposed to unfamiliar and unnatural exhibition settings, handled by unfamiliar and untrained members of the public, are subjected to welfare-compromising husbandry practices to make them more amenable to exhibition and, for nocturnal and crepuscular animals, may be required to perform at times of the day when they would naturally be resting. The low-welfare practice of keeping and training wild animals for exhibition or performance, impacting the lives of many thousands of wild animals, has no place in modern society.

• Until a prohibition is considered for introduction by the UK and devolved governments, we recommend the following urgent changes to legislation and accompanying guidance: - Inclusion of a clear definition of in-scope activities, a mandatory inspection and registration renewal process, and detailed registration conditions that must be met for premises exhibiting or training performing animals under the Performing Animals (Regulation) Act 1925; - Inclusion of a requirement for operators applying to keep or train wild animals for exhibition under the LAIA Regulations 2018, or exhibit or train performing wild animals under the Performing Animals (Regulation) Act 1925, to have undertaken formal training and received relevant qualifications in the health and welfare of the captive wild animal species they intend to keep for exhibition; - Inclusion of a requirement for inspectors of those operators to demonstrate specialist knowledge in the health and welfare of the captive wild animals species that they are inspecting, evidenced through Continued Professional Development; - Inclusion of detailed, evidence-based, species-specific guidance on the captive keeping of wild animals in the LAIA Regulations 2018 exhibition guidance and in any guidance introduced in the Performing Animals (Regulation) Act 1925 or legislation introduced to replace the Act in Wales and Scotland; - Inclusion of strict limits on travel times, exhibition times and types of performance that may be undertaken according to species in both the Performing Animals (Regulation) Act 1925 and LAIA Regulations 2018 exhibition guidance, including a prohibition on the handling of wild animals by members of the public; - Inclusion of clear guidance on what constitutes suitable housing for animals at the performance site in the LAIA Regulations 2018 exhibition guidance, and inclusion of inspection of performances at the performance site as part of the inspection process; - Annual inspection of all operators licensed under the LAIA Regulations 2018 to ensure that any welfare issues that arise are addressed within a reasonable timeframe, and that all licence conditions are being complied with; - Inclusion of a prohibition on the use of tethering of birds, both in their home environment and during exhibition, in the Performing Animals (Regulation) Act 1925 and LAIA Regulations 2018.

We call on event organisers, ranging from nurseries, schools and care homes, to corporate and community event organisers, to pledge not to exhibit wild animals in their events. There are many alternative ways to provide entertainment at events, and opportunities to engage children in nurseries and schools to learn about animals, without the use of captive wild animals.

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We call on the media industry to pledge not to use captive wild animals in their productions. Alternative methods to produce images of wild animals exist which do not require captive wild animals to perform for our entertainment. It is also important to consider the wider implications of depicting wild animals in inappropriate settings. Even if images are created without the use of captive wild animals, depicting wild animals in domestic settings risks normalising the keeping of these animals in inappropriate environments to a wide audience, and giving a false impression about the conservation status of the depicted species. For example, Ross et al. (2011) showed that people viewing a photograph of a chimpanzee with a human standing nearby, or in a typically human setting (such as an office space), were more likely to perceive wild populations as being stable and healthy than people viewing a chimpanzee without a human standing nearby or in other contexts.77 The presence of a human in the photograph also increased the likelihood that viewers considered chimpanzees to be appealing pets.77 We call on members of the public to pledge not to attend, promote or subscribe to exhibitions or activities that use wild animals. Using these animals for our entertainment is fraught with health and welfare concerns for the animals involved and may represent health and safety risks to the public. By reducing demand for such activities, members of the public can have a real impact on reducing the scale of this significant animal welfare issue.

ACKNOWLEDGEMENTS The Born Free Foundation would like to thank Dr Ros Clubb, RSPCA Senior Scientific Manager (Captive Wild Animals), for her helpful review and feedback on this report.

COPYRIGHT STATEMENTS In reference to the information obtained from Local Authorities in England, Scotland and Wales under the Freedom of Information Act 2000, as described in the data collection and analysis section of this report, we include the following copyright statements. Contains public sector information licensed under the Open Government Licence v3.0: http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/.

Contains Barnsley Metropolitan Borough Council information © Barnsley Metropolitan Borough Council licensed under the Open Government Licence. Contains Charnwood Borough Council information (document title: Animal licences - all) © Charnwood Borough Council. Contains Dumfries and Galloway Council information (document titles: FW: OFFICIAL: Case 5076614 Response to forward with attachment(s); and performing animals REGISTER (1)) © Dumfries and Galloway Council. Contains Fife Council information (document titles: FOI – Performing Animals Register FCIR:33302; _25_07_17_Redacted; Animal licence list; Fife Council 18.02.19 redacted; Fife Council 26_10_18 redacted; goat_pilates_july_19 vet report_Redacted; Performing Animals FOI; performing animals_12_16_Redacted; and vet report_Redacted) © Fife Council. Contains information from documents PAR001, PAR002, PAR003, PAR004, PAR005, PAR006, PAR007, PAR007 schedule, PAR008, PAR008 schedule, PAR009, PAR010, PAR011, PAR016, PAR018, PAR019, PAR020 and PAR022 provided by Flintshire County Council that is subject to Crown Copyright and licensed under the Open Government Licence.

FOI request regarding the keeping or training of animals for exhibition Our Ref: R148701; Licence and report AW042; Licence and report AW047; Mid Sussex District Council, 2/12/20 and 16/12/20, licensed under the Open Government Licence v3.0: http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/.

Contains Southampton City Council information © Southampton City Council licensed under the Open Government Licence v3.0: http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/.

Information disclosed under the FOI Act by Spelthorne Borough Council, December 2020, licensed under the Open Government Licence. Contains Stoke-on-Trent City Council information © Stoke-on-Trent City Council licensed under the Open Government Licence v3.0. Contains Wealden District Council information © Wealden District Council licensed under the Open Government Licence v3.0.

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-offences.

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