Is Transparency a Realistic Goal for China’s NGOs?

China Development Brief, No.55 (Fall 2012)

中文 English

…Transparency is one of the big buzzwords in China. It is seen by many as important for improving efficacy and accountability in government, business, and civil society organizations such as foundations and NGOs. Indexes ranking the transparency of foundations, NGOs and public welfare projects are all the rage in China’s third sector. But what does transparency really mean in a country where large parts of the government and business sector are not transparent, where civil society organizations are vulnerable to reprisals if they reveal too much, and where the public, long used to not being informed, is still grappling with how to interpret the information they are being exposed to? This article brings out some of the concerns and challenges that need to be recognized and addressed by transparency advocates.

As of September 10, 2012, 28 organizations had disclosed their financial records in accordance with the “USDO Financial Information Disclosure Template.”  [Editor’s Note: USDO stands for the Union of Self-Discplinary Organizations and was established in 2009 by a group of charitable organizations and NGOs to promote self-discipline and greater transparency in the sector.] This marked the first-phase of the “Hundred Public Interest Organizations Disclose Their Accounts” event. This model project has been supported by the One Foundation (壹基金) for several years.  This year, the project theme was to award “Models in Organizational Transparency.”  Up until September 10, the project had received more than 50 applications.

In March 2012, NGO Friends (恩友财务), a member of The Union of Self-Disciplinary Organizations (USDO,自律吧 ), developed the “USDO Financial Information Disclosure Template” and the “USDO Transparency Index.”  It held financial training seminars in a number of cities.  On July 13, the One Foundation announced the release of these two financial tools that it funded at the Shenzhen Charity Fair.  It set up a transparent umbrella in the exhibition as a type of performance art to draw public attention to transparency issues in the public interest sector.

In August, the One Foundation and USDO launched a “Self-Discipline for the Public Interest” event. They urged public interest organizations to join the transparency movement by disclosing their financial records through their official websites or microblogs.  USDO sent out event proposals to all its members on August 20 in order to invite more organizations to participate.  In addition, it started to collect information that had previously already been disclosed by its members.  The One Foundation and Recende CSR (瑞森德) worked to urge 93 non-USDO members to participate in the event.  USDO also sent notifications by email and QQ to the participants of its 3A financial training seminars.  On August 21, the “Self-Discipline in Public Interest” event was officially launched.  Organizers published the “2012 Self-Discipline in Public Interest” proposal in the form of a long microblog message.  Shortly after, the Shenzhen Civil Affairs Bureau (深圳民政局) published a microblog message “Disclose Financial Records, Make Public Interest Transparent” with a link to a featured report by Shenzhen Economic Daily (深圳商报). On the same day, Handa Rehabilitation and Welfare Association (汉达康福协会) in Guangdong Province took the lead in disclosing its financial records.  In order to attract public attention and lead the event in the right direction, the One Foundation invited 18 experts and scholars to participate and comment on the event.  It came to a successful close on September 7, marking an important collective action of civil society organizations in the movement for self-discipline and transparency.

After the credibility crisis [brought on by scandals that rocked Chinese charities such as the Chinese Red Cross] last year, the public interest sector had reached a consensus that transparency should serve as “the cornerstone of China’s public interest sector.” The notion of self-discipline was brought up within the sector 10 years ago. and USDO was established in 2009 to promote it.

Strikingly, even though the event was “A Hundred Public Interest Organizations Disclose Their Accounts,” only 28 organizations took the initiative to disclose their financial records.  When an organization considers whether to disclose, inevitably it has to weigh the pros and cons. This process relies heavily upon the organization’s capacity to manage and report on its finances, and is further constrained by the external environment. There is a large gap between the reality of the public interest sector and the public’s understanding of it.  When an organization decides to disclose its finances, it needs to consider its fund-raising needs and the demands of an informed public, while addressing the potential for public misunderstanding.  In addition, it needs to consider the attitude and expectations of the government and its sponsors. Therefore, promoting transparency requires efforts from both inside and outside the public interest sector.  In addition to promoting transparency and self-discipline, the “Self-Discipline for the Public Interest” event also promoted public advocacy and education.  By addressing these diverse aims, it seeks to inform the public about the role of financial data in the development of public interest organizations to create a helpful external environment.  This advocacy approach differs from advocacy that is directed only toward the sector rather than the general public.

[Some reservations about financial disclosure were raised] at the “Transparency Movement Sharing Salon” held in the One Foundation’s Beijing Office on September 4. There, representatives of two organizations which participated in the initial implementation of the “USDO Financial Information Disclosure Template” shared their experiences and answered questions raised by the audience.  One person noted, “if you look carefully, public interest organizations will always have problems. For example, how can a public interest organization properly disclose its accounts when some project expenses do not come with official receipts?  One organization on the panel answered that they would communicate with their sponsors beforehand.  Sponsors usually will permit the use of informal invoices first, then replacing them with official receipts obtained elsewhere.  Since project auditors are usually retained by sponsors, they understand the process and could handle this discrepancy between regulations and the actual practice.  Nonetheless, this process itself will not be disclosed.  Disclosure may be more difficult for those organizations that are not yet registered and those affiliated with another registered organization or foundation.  These organizations hesitate to disclose because they worry that their disclosure would cause troubles for their sponsoring organizations if their financial records turned out to be inconsistent.

[Another concern] is that promoters also see the “USDO Transparency Index” as a tool to evaluate public interest organizations, rather than simply as a self-evaluation reference tool for the organizations themselves.  Even though there has not been a detailed plan to strengthen public support of NGOs by promoting the index, the promoters of USDO have already started to clarify some fallacious rumors concerning the public interest sector through microblog and other channels. For example, one popular yet confusing topic is the issue of “zero cost” for public interest activities. In response to some foundations that state their costs are close to zero, Wu Xuebing, one of the experts attending the “Self-Discipline in Public Interest” event, commented in his microblog that the high regard for “zero-costs” charities in China reflects the low level of public understanding about charity, the lack of effective supervision over charitable organizations, and the inadequacy of tax incentives for donations.  In his view, the “zero cost” claimed by some charities does not mean that there were no administrative costs incurred, but rather that such costs were covered not by charitable donations but by other financial sources.  Tang Yilei, the Director of Philanthropy Support at the One Foundation, posted a message at her microblog to challenge those organizations claiming “zero costs.” She urged them to join the USDO “Self-Discipline in Public Interest” and to clarify their financial information, rather than playing with confusing concepts!

At the Shenzhen Charity Fair, Wang Yang, the Guangdong Party Secretary, Li Liguo, the Minister of Civil Affairs, Xu Qin, the Mayor of Shenzhen, and other leaders stopped by the One Foundation’s booth. They accepted a transparent butterfly trophy from Wang Shi, the Executive Board Member of the One Foundation.  This gift symbolizes a “transparent” charity and its  “butterfly effects.”

The understanding and attitude of government agencies towards financial transparency is crucial to the survival of public interest organizations.  Hong Bo, Director of the NGO, Qinghai Gesanghua Education Aid (青海格桑花教育救助会), posted a blog article “Is the organization doomed whether or not it discloses its finances? !”  She wrote about a disability organization that had applied for government funding: “She (a staff at the disability organization) invited some officials to inspect the organization’s rehabilitation center.  At the beginning they applauded the organization’s work.  However, the leaders lost interest the moment she told them that the organization discloses its finances according to the rules.  The leaders gave her the cold shoulder when she visited them afterwards.  A staff member at the government agency grew sympathetic when seeing her trying to apply again and again with no success.  The staff told her in private that the agency’s refusal was due to the financial transparency of her organization.”

In her blog article, Hong Bo expressed concerns about the omission of an important issue at the Shenzhen Charity Fair: how to promote a law-abiding, open, and transparent government procurement process: “I hope public interest organizations with real capacity to serve will not be squeezed out due to government procurement policies, otherwise, it will be really sad for all of us.” [Editor’s Note: Government procurement of services from NGOs has grown rapidly in the past few years, yet there are concerns that most of the government funding goes to NGOs with close ties to the government and is not being carried out transparently or fairly.]


截至2012年9月10日,已有28家组织按照《USDO 财务信息披露模板》披露了财务信息,这是“百家公益组织齐晒账单”活动的阶段性成果。典范工程是壹基金持续几年的名牌项目,今年评选限定在“透明典范”。到9月10日,已经收到50多家申请。
2012年3月,USDO 自律吧成员机构北京恩友财务开发了《USDO 财务信息披露模板》、“USDO 透明指数”,并在国内多地举办财务培训班。7月13日,壹基金在深圳慈展会推出了由它资助开发的这两个工具,并打出透明伞,意在以行为艺术的方式吸引公众 关注公益透明。
8月,壹基金与USDO 开展“自律壹夏晒公益”活动,倡议民间公益组织一起加入透明行动,参与组织可以通过官网、微博等渠道披露机构财务信息。为了让更多的组织参与进 来,USDO 8月20日向全体成员机构发送活动倡议书,开始收集之前已经披露的成员的信息;壹基金和瑞森德动员93家非USDO 成员机构参与活动;USDO 向3A财务培训班成员发送邮件、QQ 群通知。8月21日开始,“自律壹夏晒公益”活动正式启动,以长微博形式发布“2012自律壹夏晒公益”倡议书。随后,深圳民政局发布“明白晒账本,清楚 看公益”的微博并链接至《深圳商报》的相关报道。同日,广东省汉达康福协会率先晒出了自己的账单。为了增加活动的热度和引导,壹基金还向18位专家和学者 发送了邀请函,邀请他们参与活动的评论。该活动已于9月7日落下帷幕。这是民间组织在自律透明行动上的一次重要的集体行动。
然而,这次虽然喊出“百家公益组织齐晒账单”,却只有28家组织先吃了披露的“螃蟹”。要不要披露,哪个组织心里都会盘算、评估利弊。这不仅取决于内部的 财务管理能力和财务披露能力,外部环境也是一个很大的制约。公众对公益行业的理解与行业的真实情况差距很大,披露的组织如何满足筹款的需要,也能满足公众 知情的需要,还能避免因公众的误解而被误伤?此外,政府、资助方对民间组织的认知和要求也是决定披露与否的重要因素。由此,推动透明绝不是仅仅限于业内。 壹基金这次透明行动,不但推动行业自律透明,同样重视向公众的倡导和教育,行业内外“两手抓”,全方位出击,帮助公众理解财务数据对公益组织发展的意义, 也试图营造一个良好的外部环境,这是不同于以往的只对内倡导的一个面向。
9月4日下午,壹基金北京办公室举办的“透明行动分享沙龙”上,两位首批使用《USDO 财务信息披露模板》的实践者分享了自身的使用心得,并回答现场问题。有人问:公益组织的账目如果仔细找,总是会找出问题,比如,项目实施中一些无法开具发票的费用发生,怎么在公开的信息中披露?一家披露信息的组织说,之前会和资助方沟通,资助方认可将项目原始白条留着,再找其他的发票对冲的方式。项目结束 后的审计也是资助方找的,这样解决了财务规定和民间公益组织现实操作之间的矛盾,但是这些内容不会体现在披露的信息上。但有的机构尚未注册,或是以项目方 式挂靠在某一注册的组织或基金会名下。这些组织担心,如果机构和挂靠方的账目不一致,会因为自己披露而给挂靠的组织或者基金会找麻烦,因而在披露面前望而 却步。
此外,推介方还希望USDO 透明指数能被公众使用,用来给公益组织打分,而不仅仅是公益组织自评的指数。未来如何通过指数的推广,让更多的公众支持民间公益组织,尚未见到一个清晰的 行动方案,但对于社会上对公益行业的似是而非的说法,USDO 推介方已经开始借助微博等形式做正本清源的努力。比如,一个经常被提到的、也非常具有蛊惑性的问题是“零成本”问题。针对一些基金会发布的接近零的筹款成 本,这次活动邀请的专家伍雪冰在微博评论说,“零费用”慈善之所以在中国备受推崇,其原因在于公众慈善意识不成熟、慈善组织缺少有效监督、捐款的税收激励 不够等。他认为,“慈善机构宣称‘零成本’,并非是在运作过程中不产生任何行政费用,而是指公益慈善活动的行政管理费用不从慈善捐款中支取,将运作过程中 的成本通过其他途径承担”。壹基金公益支持部总监唐艺蕾在微博直接下“战帖”:与其宣称“零成本”,不如加入USDO “自律壹夏晒公益”,把信息澄清,而不是把概念搞混!
各级政府相关部门如何理解和看待财务透明,甚至关涉公益组织的生死,青海格桑花负责人洪波的博文《财务不公开是死,财务公开也是死?!》写到一家残障组织 在申请政府购买的遭遇。“她曾经邀请过有关领导来视察他们康复中心,一开始还蛮认可他们的,当说到他们的财务做得很好,所有收支都公开(时),没想到领导们从此对她没了兴趣,她再去找他们,人家就不理了。相关办事人员看她一趟趟跑政府求注册不得要领,有不忍心的,比较同情她的,私下悄悄告诉她:‘你们财务 这样子透明还怎么搞啊?’”

Liu Haiying is editor of China Development Brief (CDB).

Translated by Mu Huang

Reviewed by Helen McCabe

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