VALE has always maintained that a major failing of the law relating to live export (unlike Australia's domestic law) is that it takes no account of the suffering of the animals involved. It only counts dead bodies. And even then, there is no requirement for the government to prosecute or even investigate. Reporting of a high mortality event is mandatory....investigation by the government is discretionary.
See the government sanctioned, legal cruelty of the Australian live export trade...tonight....60 Minutes.