Navigating Philanthropy into China: A Conversation with Carol Yang, Head of Give2Asia China Representative Office

Its rich history, diverse culture, and rapid development converge to form a complex landscape that demands a profound understanding for impactful international grantmaking. Today, we have the privilege of gaining insights from Carol Yang, who serves as the Head of the China Representative Office for Give2Asia.

With her extensive experience and expertise in leadership, philanthropy, and grantmaking within China, Carol offers invaluable insights into the intricacies of grantmaking into this diverse and dynamic nation. Throughout this interview, we will explore the most pressing China questions concerning donors, foundations, and investment managers, and leverage her expert knowledge of the strategies, opportunities, and challenges for those aiming to make a lasting impact in this ever-evolving landscape. 

Without further ado, let’s dive in! 

Question: Let’s start with the basics. How does Give2Asia’s China Representative Office work within China?

Answer: Give2Asia was one of the first overseas NGOs to register a China Representative Office (CRO) in China after the passage of the Law of the People’s Republic of China on Administration of Activities of Overseas Nongovernmental Organizations in the Mainland of China (ONGO Law) in 2017. We are registered with the Overseas Nongovernmental Organization Management Office of the Beijing Municipal Public Security Bureau (PSB).  

In its day-to-day operations, the CRO collaborates with four key parties:

• PSU & PSB: Operating in compliance with the ONGO Law, the CRO works closely with the Professional Supervision Unit (PSU) as well as the PSB, following their guidance and oversight. All China grants by Give2Asia require full approvals from these authorities. CRO maintains continuous communication with them, addressing annual activity plan (AAP) submissions, approvals, regular PSB monitoring, and annual activity report (AAR) submissions. 
• Grantees: Give2Asia CRO partners with local Chinese nonprofits as grantees to implement projects. CRO staff actively support grantees throughout the grantmaking process, including project design, pre-compliance evaluation, AAP submissions, due diligence checks, project proposal and budget development, disbursement, and ongoing communication to ensure legal and smooth project execution. 
• Give2Asia HQ: CRO maintains daily communication with Give2Asia HQ, ensuring seamless alignment and delivery of information to support the achievement of philanthropic goals in China for our donors. 
• Donors’ China Staff: Many of our corporate donors have in-country staff and CRO collaborates closely with these China-based teams to enhance coordination and efficiency among the donor’s HQ, their local team, Give2Asia HQ, and Give2Asia CRO.
  

In addition, CRO has worked directly with our local nonprofit partners to develop three signature programs: the Rural Doctor TCM Training Program, the Tomorrow-iCAN Program, and the COVID-19 Heroes Legacy Program. We cooperate with China Friendship Foundation for Peace and Development (CFFPD) and Shenzhen Henghui Charity Foundation (Henghui) to implement these programs. We work with Give2Asia HQ to fundraise and actively participate in the research, program design, and implementation monitoring. As a part of CRO’s core work, we try to effectively address the “last mile” needs of beneficiaries while providing our donors with trusted programs to realize their philanthropic strategy. 

Q: What is Give2Asia’s overall process for making grants into China?

A: Give2Asia CRO sits at the intersection of Give2Asia HQ, Chinese grantees, donors, the PSU, and the PSB. The processes can be a little intimidating, so we created a flow diagram to help provide some clarity: 

China Grant Approval Cycle

Q: That’s quite involved. How long does it take to get all the necessary approvals?

A: To ensure grants can be approved, CRO staff give professional advice to donors and grantees in compliance evaluation before submission of the AAP for each specific grant. This means we review the proposed project plan and perform a risk assessment for any potential violations to U.S. or Chinese laws or possible concerns from the PSU or PSB. It takes about 3 to 4 months to receive full approval—2 to 3 months for the PSU to review and approve grants and about a month for PSB approval. That said, approval times may vary depending on the types of projects and activities being implemented; the PSU may consult with relevant departments or local governments for professional input during the approval process.  

Q: Do you anticipate any change in this procedure in the near future?

A: We don’t anticipate significant changes in the procedure in the near future. However, we can see a trend of a stricter, more professional, and more ordered AAP approval process. In recent years, the PSU and PSB have begun to adopt various measures to seek more professional advice from other related departments and have a deeper and more comprehensive understanding of all grants. This indicates an increasingly detailed and rigorous monitoring process for overseas charitable activities. The CRO’s work is very transparent and compliant, so we proactively communicate with our PSU and PSB to cope with their monitoring requirements.  

Eventually, we believe it will provide long-term benefits to our works and efforts in China to be implemented as a more professional and detailed monitoring will create an increasingly open and healthier philanthropic environment towards overseas donations in China. 

Q: So, in your experience, which areas of grants have the highest approval rates? Which areas have the lowest approval rates? Are there any projects or geographies that are more or less likely to receive government approval?

A: The CRO has an outstanding AAP approval record. Over the past 6 years since it was established, we’ve submitted thousands of grants for AAP approval and only saw one rejection. From our experience, different types of grants may have varied approval times, as some of them take longer to deal with back and forth of additional information and clarifications. For example, grants related to education and the environment may have longer approval times. These types of grants may lead the PSU and PSB to pay more attention to ensure no potential political or national land security issues are attached during the approval process. 

In terms of geography, the PSU and PSB will typically approve all compliant grant activity across all provinces, cities, and autonomous regions in mainland China.  There are rare cases where the local government is more conservative or cautious about receiving overseas funds and will be unwilling to support a grant proposal. This is because of the local governments’ varying levels of understanding of the international environment and Chinese policies among different regions. That said, a local government’s lack of support of a grant proposal in one location does not necessarily mean wholesale rejection of a grant proposal. Grants designed to work in certain locations can be adjusted for other locations where the local government is more experienced and open-minded, and this is supported by our PSU and PSB.  

Q: You mentioned the local government being unsupportive of a proposal over political concern. Would you say that is becoming more common? What are the biggest challenges and risks of giving into China right now? What does Give2Asia do to mitigate them?

A: We still only see sporadic cases. But there are always challenges as we are facing an increasingly complex international geopolitical environment. Although the Chinese government at the state level still welcomes and supports our grants, it is unavoidable that some local governments and institutions do not understand or even make excuses not to support grants donated from overseas.  

Against this background, our grantmaking is not just a matter of giving and receiving. It involves coordination of many parties. For example, the implementation of an education grant may involve the local educational authorities, schools, teachers, students, students’ parents, and even wider communities. Either party can participate and have options and opinions. When our concept understandings are aligned, the project may be implemented smoothly, but when there is inconsistency in any links or parties, we can only continuously seek solutions.  

As a result, CRO staff needs to maintain regular contact with each stakeholder in a complex and dynamic environment. We are working hard to communicate with our PSU and PSB, and with our grantees to analyze the project situation and facilitate solutions. 

Q: Moving beyond the approvals process, what if a major change needs to be made in the middle of a grant’s implementation? What is the process for moving forward?

A: These types of needs typically originate from the grantee when they recognize changes to the target population’s needs or identify the necessity for a budget reallocation. When this occurs, the grantee will first notify CRO staff about the change. We then determine whether the change needs an AAP resubmission. Normally, changes involving relocation or major adjustments to project amount, objectives, and activities require AAP re-approval. CRO staff will work with the grantee to fill out an amendment/reallocation request to clarify the specific changes, reasons, and the revised plans that need to occur and submit the AAP amendment in the soonest window if needed. In the meantime, requests are reviewed by Give2Asia CRO and Give2Asia HQ, then sent to the donor for final approval. Once the amendments are approved by the donor and our PSU and PSB, Give2Asia CRO will send an official email confirmation to the grantee, after which the grant can be implemented according to the revised plan or budget. 

Q: What about the fee structure? How do fees for grants to China differentiate from fees for other grants?

A: Our fees for China grants are higher than the fees for grants to other countries. This is mainly because of significantly higher administrative costs and additional responsibilities.  

Grantmaking into China takes longer and involves more work than into other locations. The AAP process alone involves a pre-compliance evaluation, preparation of AAP submission documents, PSU & PSB coordination, grantee and donor communication, and so on. Most documents submitted by Chinese grantees are in Chinese, which need to be translated for U.S. donors. After grants are approved, CRO will also make extra efforts to cope with the local PSB’s rigorous monitoring.  

At the same time, the CRO works with the corporate donors’ China-based staff to better coordinate with their CSR strategy on DAF grants and provide consultations throughout the lifetime of a grant. 

Furthermore, CRO is the grantor of all grants in China and bears all related legal liabilities, meaning that we take responsibility for any wrongful actions regarding safety and security. Thus, CRO devotes a great deal of effort to risk assessment and mitigation. We pay special attention to due diligence, project implementation monitoring, project risk management inspections, and so on. 

Q: How can grants made to China be publicized in the U.S. vs. China?

A: There is no regulation for donors to publish or promote details of a grant outside of mainland China. Within mainland China, communications should align with the following under the Chinese ONGO law: Give2Asia is the grantor of the grant and bears all legal liabilities associated with the project which it manages. Give2Asia must be referred to as the grantor in all publicity activities or materials within China.  

We suggest using the following language: “This project is sponsored by [DONOR] and is granted and managed by Give2Asia.” In Chinese, this is “此项目由赠与亚洲(美国)北京代表处捐赠管理”. 

For corporate donors, either the company name or the corporate foundation name can be used with Give2Asia’s name mentioned alongside. Any use of corporate logos or corporate foundation logos are allowed when Give2Asia’s logo is also represented according to the visibility requirements from the Chinese government. 

Most importantly, we advise donors to make sure any publicity within China is reviewed and approved by Give2Asia CRO’s staff before publication. We will always provide guidance to ensure all your content is compliant. 

Q: As we wrap up, do you have any final tips or advice you would like to share with donors who are considering making grants to China?

A: My advice for donors is to trust Give2Asia and work with us. Together, we will make our charitable endeavors be implemented with the maximum impact and efficiency while remaining in compliance with domestic regulations.  

I also suggest donors who have staff within China to listen to their China-based staff’s ideas and opinions. These staff have firsthand insights into the political & micro-economic circumstances, and social development needs in China, which is invaluable for making meaningful grants and achieving philanthropic goals in China. 

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In closing, we extend our gratitude to Carol Yang for sharing her vital information and expertise on grantmaking into China. Her extensive knowledge and experience provide crucial insights into the intricacies involved in philanthropy within this diverse and dynamic nation. 

We hope that this conversation has shed light on the many opportunities that await philanthropic endeavors in China. If you are inspired by this discussion and eager to begin your grantmaking journey, we encourage you to reach out to us to start the conversation!