New jobs have been created, namely sustainability directors, managers, officers, consultants; as have new organisations and networks.

While companies have invested in the SUStainability game, they have invested nothing in the corresponding transparency. Let’s be clear, sustainability without the corresponding transparency is just a ‘SUS’, neoliberal ideology to maintain shareholder primacy.

As a very minimum, radical supply chain transparency is needed to take the SUS out of SUStainability Game.

It has only been in the last couple of years that some of the big players in conservation have started to openly state that the legal trade is at least 10 times higher in value than the illegal trade, and, despite this, very little good quality, complete data exists. In 2025, some in conservation have started discussing that the sector must Evolve or Perish, based on, “the need to fundamentally reconsider what we label ‘success’. Often, outputs rather than outcomes are celebrated, many stopping short of conservation impact”.

While this statement is true, what isn’t acknowledged is that the limited conservation results of tackling wildlife crime have been because a key suspect was taken out of the frame. The reason so few inroads have been made in dealing with wildlife crime is because in reality there is too big an overlap between the illegal trade and corporate, green crime. Business surveys show that companies know that green crime exists in their supply chains. They also know they can carry on with impunity because there is so little appetite to deal with corporate crime; as a consequence nothing decisive will/can be done in dealing with the illegal trade in wild species.

1. A substantial 65% of respondents know or suspect that third parties they conduct business with may have been involved in a range of illegal, environmentally damaging activities.
2. Only 16% of respondents say that they would report a third-party breach externally and only 53% said they would report it internally.
3. Critically, 63% of respondents agree that the economic climate is encouraging organisations to take regulatory risks in order to win new business.

The report (again) confirms why it is so easy to launder illegal product into the legal supply chain and marketplace. and this survey was done pre-COVID pandemic. Monitoring and regulations in trade were softened in many countries under the guise of a Covid-19 economic stimulus strategy. 

While the levels of green crime outlined in this report go beyond the CITES trade in wild species, it is important to note that many of the countries highlighted in Figure 2.7 of the report still use 1970s paper permits to facilitate their trade in CITES listed species. For example, Spain where 83% of respondents know or suspect that third parties they conduct business with may have been involved in a range of illegal, environmentally damaging activities, still uses CITES paper permits, as do India (75% of respondents), Russia (82%), Canada (67%), Germany (61%), the Netherlands (59%), the UK (45%) and more. These wealthy countries, and the companies that call them home, have not taken the most basic, pragmatic steps to ensure that illegally harvested wild species can’t be laundered into company supply chains. 

In a world where big data rules, to provide a competitive advantage in the globalised and hyper-competitive world of business, the systems, such as the CITES,  have been left to languish in a pre-digital world. This is no mistake. Opaque, ineffective monitoring allows businesses and industries to maintain plausible deniability of their role in the biodiversity crisis. They can continue their all profit, not responsivity approach expected by their investors, as a result of the shareholder primacy model.

Maybe Figure 2.8 of the report is the best indicator of how much business know they will not be held accountable for their role in the global biodiversity crisis. And specifically, the UN Sustainable Development Goals 12 (Responsible consumption and production) and Goal 15 (Life on Land). Of the global business surveyed only 15% are “trying to support” SDG12 and only 17% are “trying to support” SDG15. Given this report was published in 2020, it is likely that commitments to these and other SDG goals have dropped, in the global push to reduce already ‘non-excitant green compliance’. 

The failure of supply chain management, highlighted by this 2020 survey, enabling industrial scale green crime represents a failure of business, industry, markets and investors. It is time to demand that all businesses, including personal luxury (clothing, accessories, Jewellery, beauty, wellbeing etc), high-end furniture and housewares, luxury hospitality, fine dining and gourmet food and the exotic pet industry, involved in the trade in endangered and exotic species, invest in their inadequate supply chain management systems. Without this the SUStainability reporting is simply ‘SUS’, with the only option being, No Transparency – No Trade.

It is important to remember that after seafood, fashion and furniture are the industries making the biggest profit from the extraction of wild species. The supply chains of the luxury sector need investment to become radically transparent to protect the endangered and exotic species the industry uses as its raw materials for apparel and accessories.

According to Fashion Revolution, “Luxury brands are notorious for being opaque about their supply chains and have long lagged behind other market sectors when it comes to transparency. The elite fashion houses try to create a sense of exclusivity around their products, leaving most details about the production and impact of their products a mystery”.

When it comes to creating a ‘sense of exclusivity’, perhaps the Hermès Birkin and Kelly Bags have perfected how to drive consumer behaviour by creating something that is perceived as having a unique value. The Birkin Bag even has its own sculpture, by Kalliopi Lemos, titled Bag of Aspirations.

It isn’t unusual to see these to two bags listed as the most expensive bags in the world, even when purchased second hand, because they are too difficult to source new. They have become a regular item at Sotheby’s auctions.

A huge investment is made at the retail end of the supply chain to create the ‘sense of exclusivity’ discussed earlier, but is the same attention paid to the raw materials end?

Let’s look at two species used as the raw materials in the production of the Kelly and Birkin Bag, the Nile monitor lizard and the Nile crocodile. 

A search of the CITES trade data shows the same problems found in previous investigations. Click on image to enlarge. 

Namely, “The Group’s strategy is to better understand its supply chains, strengthen them with high expectations to ensure their quality, ethics, environmental and societal sensitivity, and develop them to anticipate future growth. This approach is based firstly on compliance with the regulations concerning the various materials. This notably means legislative provisions: ensuring compliance with the Washington Convention (CITES), an agreement between States for the worldwide protection of species of flora and fauna threatened with extinction”.

Given the scale export/import discrepancies outlines in the examples for just two species, this makes any company statement on compliance with the CITES meaningless.  

Year-after-year CEOs highlight supply chain traceability is the top priority, yet little changes. There may be some minor investment into third party certification schemes. But these are just voluntary, not mandatory and, in the main the information isn’t publicly available for independent validation purposes.

When you contrast the significant investments made by the luxury industry to drive up the desire for their goods and services (e.g. on average the luxury industry diverts 8% of its turnover into funding advertising initiatives), to the fact that the system that monitors the extraction of the ‘raw material’ languishes in 1970s technology, then it is obvious that the industry has zero interest in transparent supply chains and the sustainability of the wild species it uses.