INTEGRITY, TRANSPARENCY AND ACCOUNTABILITY IN NONPROFIT ORGANIZATIONS

Abstract

In the midst of extensive calls for NGOs to become more accountable and transparent, this paper examines the prevalence of discrepancies between what NGOs say and what they do. Nonprofit organizations grew up sporadically during the 1990s, with an outstanding account of local and international human rights organizations. However, during the last decade, these agencies have come under sharp condemnation, with allegations that NGOs often lack the integrity and transparency that they are known to loudly demand from governments and their private sector counterparts (J. McGann & M. Johnstone, 2006: 66). Responding to this growing lack of confidence on the sector, in June 2006, eleven major NGOs signed a leading international NGO Accountability Charter, a voluntary statement of principles and policies. Signatories included Amnesty International, Greenpeace, Transparency International, and Oxfam. Even though the charter is not enforceable, such an open declaration represents a significant step in the evolution and maturation of global civil society. This paper will look at the question of NGO accountability, with a strong focus on the particular challenges facing human rights NGOs, whether they are domestic or international in scope. 

Methodology of the Research

This research is based on a number of secondary literatures of unique information on local and international NGOs. By probing the untruthfulness of NGOs with regards to financial transparency and the level of community participation, the study will particularly seek to investigate whether there is a higher level of issues of misrepresentation among NGOs. This research will attempt to follow the Heckman Probe it Model-a model which suggests that the determinants of misrepresentation differ according to the subject matter: the threat of being caught reduces the likelihood of dishonesty of financial transparency, whereas, the desire to preserve a good reputation seems to be the factor of not meeting the true needs of the community (Michael E. Sobel, 2005). 

Introduction

Nonprofit organizations (NGO) are well known for undertaking a wide range of causes. Like all government regulated agencies, NGOs abide by a set of strict ethical principles, mostly defined in voluntary codes and standards. When teaming up with government and corporate social initiatives to promote wider causes, NGO are important partners that have proven to be effectively selfless. Because of that, they are held in high esteem. 

These days, NGOs are facing a number of different challenges. The effect of globalization, the rising standards of living due to the recent global recession, advancement of technology, and others, continue to impact the ways in which nonprofit organizations do business. The level of involvement by NGOs has expanded, to include social services, human rights advocacy, dependent care; immigration, fight to eliminate diseases (HIV & AIDS), and serve as pressure groups in favor of humanity (Eisenberg 2000). 

A number of NGOs are partnering with private foundations, such as the Bill and Malinda Gates Foundation. Because of their sizes and scope of operations, most of them manage large resources. This has prompted the reconsideration on the principles that governs NGOs, i.e. the way they are organized, run, and conduct business. As social and political actors, NGOs must conform to the rules of ethics and honesty. Those who advocate self regulation of NGOs are mostly concerned about governments’ interference on how business is conducted at the nonprofit level, arguing that government’s supervision would undermine the sector’s autonomy (Jordan and Van Tuijl, 2006). 

Those who are against the regulation of NGOs by government are strongly convinced that allowing government to regulate the activities of NGOs will undermine the sector’s autonomy. On the other hand, the risks associated with self regulation are rarely mentioned. Nonetheless, there is a general belief that NGOs are well intentioned. NGOs carry this underdog personality as the innocent victims, while the government is seen as the bully, interfering with the noble tasks of NGOs. 

In an attempt to balance the debate, this paper will investigate the claim that NGOs are sometimes urged to make decisions that are devious, unguided, and self-interested. Ronelle Burger and Trudy Owens (2008) state that the presence of NGOs in developing countries with high unemployment is a blessing in disguise as they symbolize a huge share of a nation’s revenue pool. With this in mind, it may be unwise to hold the assumption that only people with benevolent and pro-social intentions are mostly passionate about this sector. 

The paper will exploit different studies and assumptions to induce broader discussions about what NGO accountability should look like in practice, seeking to address the most difficult questions of accountability often center on the balancing of interests of different stakeholders. The paper will attempt to review the range of legal and regulatory frameworks currently in place domestically, regionally, and internationally; while recognizing that true accountability more than likely will depend on voluntary systems put in place by individual agencies.

Accountability and Transparency in the NGO Sector

Georgianne Nienaber wrote in the Huffington Post on (July 13, 2010), that according to a new report by the Disaster Accountability Project (DAP), there is dismal lack of accountability by relief organizations that received over $1.3 billion as aid for Haiti, six months following the quake disaster that hit that nation in January of 2010. In addition, Nienaber (2010) states that out of 197 organizations which sought for funding to support their humanitarian activities in Haiti, only six provided factual situation reports detailing their activities-128 organizations had absolutely no reports on their websites other than emotional requests and sketchy description of activities.

Research has indicated that transparency is mostly based on the recognition that people are infallible-that society has put in place a system of checks and balances to identify mistakes, lapses, and inaccuracies made by people and organizations (J. Stieglitz, 1999: 23). In view of this, transparency is then seen as the prerequisite for the efficient running of such checks and balances. However, without an accurate and timely information, stakeholders will find it impossibly harder to hold decision makers liable, Stieglitz (1999). 

Lisa Jordan and Peter van Tuijl (eds., 2006) holds that given the enormity of private information and resources found in nonprofit organizations, transparency should be vital to the sector. On the contrary, the relationship between stakeholders and NGOs are filled with information blackouts, because of that, it makes it extremely difficult for beneficiaries, Government regulators and donors to identify potential problems and hold people accountable in the NGO sectors (Jordan & Tuijl, 2006). For instance, those who provide funding for these NGOs are in the West, while a number of NGOs are doing business in Africa and Asia, and because of that, there is a disconnect between donors and beneficiaries, visa vie, nonprofit agencies. For important information on the activities of NGOs, donors have to rely on secondary sources, especially when there is not an impartial monitoring and evaluation mechanism in place. Jordan and Tuijl (2006) therefore argued that when donors are not familiar or abreast with the realities on the ground, i.e. culture of beneficiaries, actual cost of running operations locally, it seems impossible to effectively assess the efficiency and credibility of a humanitarian agency. 

Why Accountability and Transparency are matters of human rights, equality, liberty, and justice?

Jessica Schultz & Tina Soreide (2008: 516-536) states that most agencies in relief work are engaged in helping people in need of justice, basic human needs, and others. Therefore those who are involved with relief work, including donors, government offices, and NGOs have written procedures to follow. The study argues that most NGOs follow the internationally standardized protocols on procuring goods and services for their beneficiaries, which is in keeping with human right standards. However, the deviations come from misuse of legitimate derogation from the rules depending on the situation at hand. For instance, since most emergency situations threaten lives and public safety, some of the mediums used to distribute aids, though most of them are done in writing, a number others are not done informally. One immediate example has to do with ‘value for money’; in procuring relief goods and services, this is where the actual value for a given item is not immediately matched with the quality of that item during an emergency situation. A second situation has to do with hidden violations of procurement rules-where it appears that normal procedures have been followed. Schultz & Soreide (2008) cautioned that during emergency distribution, people may use tactics like exaggerating the severity of emergency situations, misuse discretionary powers reserved for emergency, misuse lax requirements for written justifications, among others.

The study also stated that corruption can almost certainly occur in circumstances where it may appear that all standard procedures were respected. For instance, by using limited innovation, bids may be placed out, but they are done in ways where the bribing supplier is the only agency informed in a timely manner, or calls may go out to only a handful suppliers, but very late. Or sometimes, the announcement is communicated to fake suppliers that are not in the position to supply the needed items or services. There are times when signatures are forged on bids by one agency providing several other proposals on different letterheads to create the notion that they came from rival agencies. In concluding, Schultz & Soreide (2008) went on to name misuse of information, where one bidder may bride someone internally to obtain information on a rival bidder; it also hold political and diplomatic pressure as another mitigating factor, this is where local politicians are used to influence the outcome of a bidding process. 

Two separate studies advocated that beneficiary oversight may alleviate the deficiencies in donor information. They stated that it could be difficult for NGOs to conceal information or activities from beneficiaries due to their level of engagement in the processes (J. Tendler 2000; G. Mansuri & V. Rao 2004). Contrary to such a view, lack of education or the ability to understand the process may prevent illiterate parents from making informed judgments as to the quality of education that an NGO is providing their kids. Those same studies believe that beneficiaries who lack the ability to thoroughly critique or evaluate the services they are getting, may contribute very poorly to the overall evaluation of an NGO (Veron, R., Williams, G., Corbridge, S. and Srivastava, M., 2006; Plateau, J-P, and Gaspart, F. 2005). 

The rationale to the argument is that, those beneficiaries who lack the capacity to evaluate the services they are receiving, may be quite satisfied with the minimal services provided by an NGO as opposed to not getting anything at all (Veron et. al, 2006; Plateau & Gaspar, 2005). Moreover, other studies have shown that beneficiary involvement in the monitoring and evaluation of NGO services may be up for a number of gimmicks by managers of NGOs who are skillful to conceal information from members of the community (Olken, B.A. 2005; Olken, B.A. 2006). Besides, separate studies have discovered that low self esteem of community members may prevent those members from decisively taking up issues against those who manage the outcomes of a nonprofit agency (Ronelle Burger, 2005; Kihato, C., and Kabemba, C., 2002). 

The question is why would an NGO choose not to be transparent? Why would they want to misrepresent their financial dealings and level of engagements in the community? Ronelle Burger and Trudy Owens (2008) believe that the following may be the reasons why NGOs may chose to conceal information: “having something to hide, having a motive to hide it, being able to hide it and an indifference to concealment of the truth”. Burger and Owens (2008) stated that NGOs may have to hide information if they have misallocated funds, i.e. deviating from the expectations of donors and beneficiaries; they may choose to hide information if being opened ruins their reputation or reduce public confidence on their operations; another factor that influences NGOs to hide information is unreasonable pressure and demands from donors.

Research has outlined the difficult and sometimes conflicting demands that NGOs frequently have to put up with, i.e. the expectations of beneficiaries, donor’s commitments, community expectations, are few competing factors that NGOs have to cope with in addition to their own mission and obligations (Alexander, V.D., 1998). Accordingly, the study argued that one good tactics to avoid all of these competing factors is deflection. This is where the organization tends to limit the amount of external complexities it puts up with through the use of misrepresentation. For instance, in fiercely competitive funding atmosphere, NGOs that want to resist rigorous donor intrusion may avoid the rift by misrepresenting its activities. Sometimes, NGOs misrepresent their activities positively due to funding pressure (Alexander 1998). One survey conducted by M. Bolton in 2003 found out that annual reports of NGOs are predominantly positive, and outlining the accomplishments of the organization. 

But no matter the reason for NGOs to misrepresent their activities, the various arguments outlined provided the basis for additional debates and concerns of deception in the NGO sector. For instance, in addition to the various reasons given for deception and misrepresentation, some thinkers have evaded these ethical concerns with various models that tend to justify the actions of NGOs. They contended that NGOs have limited opportunity to manipulate information on their activities. For instance, based on the contract failure theory (E. Thompson, 1980; H. Hansmann, 1980; E. Fama & M. Jensen, 1983) argued that the expectation for NGOs to behave more openly where deceptions are possible, is fully operational. For instance, in circumstances in which for-profit companies lower their overheads by reducing the quality of their goods and services, because nonprofit organizations are not profit driven, and are subject to non-distribution restraints, they do not have the need to cheat or misrepresent their activities. Accordingly, the non-distribution mechanism stifles the ability to create residual earnings for managers of NGOs, an option which is usually off limits in for-profit organizations. 

But David Cruse Malloy and James Agarwal (2001) identified a framework for nonprofit organizations that is distinct from the for-profit orientation. They put forward and discussed ten propositions, and along with their implications. These writers stated those ethical beliefs vary from organization to organization. What that means is that what is considered unethical by one, could be ethical to others. By having the luxury to determine what is ethical from what is not makes this issue trivial. Because, like for-profit organizations, nonprofit agencies are bound by a set of strict ethical expectations, for instance, Malloy & Agarwal (2001) cited the case of the Canadian Red Cross, a nonprofit organization, which knowingly allowed tainted blood to enter its blood bank. Besides, a number of these nonprofit organizations are used by Federal and state authorities to better manage their programs, and because of that, nonprofit organizations are bound to uphold the greatest ethical standards if they should continue to enjoy greater public confidence, Malloy & Agarwal (2001). 

Although a number of ethical studies were have been done on for-profit organizations, Malloy & Agarwal (2001) paid particular interest on the ethical climate within nonprofit agencies. The study holds that all activities for nonprofit agencies must be community driven, void of self interest or profit driven, and must be opened for scrutiny. 

No matter the outcomes of these studies, each of them is bound by their individual limitations and biases. For instance, the contract theory on the one hand relies heavily on the non-distribution restraint, and besides, it is ambiguous since it did not precisely tell how using it will not be profitable to managers of NGOs. Furthermore, the categorizations of surplus, profit, private gains and residual income, are all matters of accounting principles that can easily be masked as overstated expenditures and salaries, unreasonable bonuses and benefits that could only be detected by rigorous auditing standards (Burger and Owens, 2008). 

Apostolou, Barbara; Thibadoux, Greg M. (2003) stated in their acclaimed work, ‘Why Integrity Matters’, that an auditor treats each individual material assertion as a working hypothesis or scheme in need of evaluation. Therefore, a series of appropriate tests is conducted on each to generate evidence. Following the generation of sufficient evidence, the auditor then makes a determination or judgment about the credibility of the hypothesis. Accordingly, auditors are compelled by reason of due diligence, to evaluate the composite reliability of the proposition, and hence the validity of an entire financial statement in general. This thorough and well defined process that is discussed in Apostolou & Thibadoux (2003), lends credibility to both the financial statement and the auditor’s report. Rappaport, Roy A (1999) refers to the auditing process as the lie and the alternative. And because of lack of transparency and the inability to conform to such standards, NGOs financial reports are for most part, subjective, and do not have the required auditing credibility that for-profit organizations conform to. 

Invariably, (Thompson 1980; Hansmann 1980; Fama & Jensen 1983) previously made the case that because of its level of openness, NGO sector is likely to attract honest people. But because of the issue of lack of transparency as discussed in (Edwards, M. and Hulme, D., 1996), and as cited by Burger & Owens (2006); and coupled with the many issues of poor track record, inability to effectively monitoring and evaluating the activities of these NGOs, their inability to pay taxes due to tax exempt status (501(3-C), coupled with their version of services provided to beneficiaries, one may choose to argue on either side, even though the side against the NGOs seems to have a stronger case. 

Summary of major challenges

There are two arguments at play here. One has to do with the motivations of donors; Peter Nunnenkamp, Janina Weingarth, and Johannes Weisser (2008) argued that the need based allocation of donors has shifted from egoistic demands, to altruistic. The study further stated that since the late 1990s following a World Bank speculation that government to government transfer of aids do not mostly get to the intended beneficiaries, it was then believed that NGOs have the competitive advantage to work in difficult environments.  Nonetheless, the argument put forward earlier by Edwards & Hulme (1996), that NGOs have a clear focus on the poor and needy no longer holds.

The question is what do donors hope to see made out of donations to NGOs?  In line of this, Fisher (1997) as quoted by Nunnenkamp et al. (2008) argued that "while the moniker 'nongovernment organization' suggests autonomy from government organizations, NGOs are often intimately connected with their home governments. Therefore, the dependence of most NGOs on government funding is expected to shape their aid allocation.  To the extent that they follow their official back-donors; their aid allocation would no longer be superior in terms of targeting the needy and deserving. But one cannot wholly rely on one circumstance to judge the intentions of all donors. One thing is certain, that donors are not intending to receive a market return on their investments.  And again, not expecting a market return on a generous donation is not a stronger argument to categorize the intentions of all donors. 

According to Rose Ackerman (1996), because there are no threats of mergers and takeovers in this sector, managers of NGOs are fond of dodging their donors. The second of the two arguments is the claim made by Malloy & Agarwal (2008) that because NGOs operate under the value of non-distribution, they are likely to attract employees who are selfless and underpaid. But Brinkerhoff & Brinkerhoff (2002) argued that since NGOs thrive on non-distribution constraint, the pool of managers will not only sort themselves out automatically, the more public-spirited and value-driven ones will be heading for the NGO sector, while the self-seeking and profit-driven ones will be going to the private sector. The utilitarian argument will then be that only people who derive utility from helping others are passionate about a sector that pays below market rates. Moreover, nonprofit are perceived to be more caring and trustworthy not only for the individual, but for the community as a whole (Malloy & Agarwal, 1999). This model can only be sustained with a much stronger assumptions about labor market, with a more empirical basis.  

Research on motivation in the NGO sector concludes that there is very little justification that the sector is altruistically non-financially motivated (Weisbrod, B. A., 1998).  In the absence of a thorough scrutiny of the activities of NGOs, no one can precisely provide a more accurate picture of these issues from the nonprofit perspective. For most part, research surrounding the ethical climate of for-profit organizations is voluminous. Nonetheless, few studies on the ethical climate have been done on the context of NGOs (i.e. Agarwal & Malloy, 1999; Brower & Shrader, 2000; Deshpande, 1996a & b; Malloy & Agarwal, 2001, 2003). Interestingly, (Rasmussen et al, 2003), a qualitative research found that nonprofit sector is mostly preoccupied with concerns of individual caring, independence, and team caring as the prevailing ethical issues.       

Expected Outcome to Implementation of Recommendations 

As a sector, nonprofit has traditionally faced limited government regulation, and because of that the segment is self regulated and lacks the level of discipline and control mechanism found in the private and government sectors (Burger & Owens, 2008). Accordingly, for profit and government sectors thrive on public, private, and consumer ratings and feedbacks to improve their quality of services, NGOs lack those competitive and rigorous mechanisms that induce or motivate them to improve their standards of delivery for their beneficiaries. Government and private sectors have standards and legal regulations that compel them to reconsider their managerial strategies. Those who benefit from the services of NGOs have little or no say on the running of most nonprofit organizations (Malloy & Agarwal, 2003). The inability for beneficiaries to query or critique the level of services they are getting from NGOs, and coupled with the inability of NGOs to be regulated by the state and, or their donors are factors that hamper the implementation of these recommendations.

 

Another factor that will hamper the implementation of these recommendations is the inability to get access to important financial information of NGOs. Furthermore, the increased level of gap between donors who are mostly in the West, to actual operation sites and beneficiaries and NGOs, is another factor that hinders implementation.  In addition, the low level of employment in developing countries where these NGOs do business, and coupled with the scanty presence of inexpensive entrepreneurial and self employment opportunities, it may not be a wise idea to believe or garner the feeling that a sudden deviation from the normal way of doing business will be welcomed. A number of NGOs are in environments that lack the level of institutional and hearty legal atmosphere that will force them to stick to their professed goals and missions (Rasmussen et al, 2003).

  

Conclusion and Findings

Based on the findings of the many research materials dealing with the issue of transparency and accountability of NGOs, this paper recommends that caution be taken against various widely held beliefs about the NGO sector. When monitoring, regulating, or evaluating activities of the sector, due diligence should be used on information put out for public scrutiny. This paper also recommends an increased level of independent verification of the sector in order to evaluate its effectiveness in service delivery, and ensuring that beneficiaries are getting what they deserve. Although most NGOs reject some form of regulations, especially state sponsored processes, mechanisms should be put in place either for effective auditing of all activities, in exchange for continued funding of programs. Based on the philosophy on social values and self-sacrifice of most NGOs, this should not be a problem if set as a precondition to funding.     

Based on most of the materials researched, there does not seem to be a strong link between the professed selflessness, and level of proficiency of NGOs to the twisting of information that seems to be norm in the sector. Nonetheless, the triviality of selflessness ascribed to the sector may imply that a number of NGOs use practical approach to create an ethical climate as stated by (Malloy & Agarwal, 1999). More likely, those who continue to class NGOs as selfless may not be actually focusing on the quality of work or services, but rather on their professed philosophy, or as a sector in general. Given the hardened position of most of the literatures on the level of misrepresentation and outright deception within the sector, a number of NGOs consider these findings inconclusively biased. One of the most widely held belief of this research is that those NGOs that are actually selfless may be willing to deviate from their normal ways of doing business for the greater good of their stakeholders. This paper likewise concluded with others that having the fear or suspicion of state monitoring and regulation may lead to fear and dishonesty.

The paper also subscribe to the view that unrealistic and excessive demand from donors of NGOs could result to misrepresentation. But there does not seem to be a correlation between dishonesty and corruption and ineffectiveness that were pointed out by Rasmussen et al (2003) and many others. A number of these biases could be attributed to the lack of adequate information on the activities of NGOs.. On the issue of deception and corruption, this paper found that a number of NGOs may engage in lying based on isolated cases, i.e. fear, safety and security. On financial transparency, there are indications that the main reason for not being transparent is largely due to the inability of comprehensively and inability of NGOs to effectively manage their records and activities, and especially on matters of emergency, are contributing factors. Accordingly, in a bid to save face or show justification for funding or it use, most NGOs misrepresent their level of involvement within the community. A number of NGOs need to incorporate ethics training into their regular yearly activities to significantly reduce the level of misrepresentations made to stakeholders.      

        

References

Alexander, V.D. 1998. Environmental Constraints and Organizational Strategies: Complexity, Conflict, and Coping in the Nonprofit Sector.

Bolton, M. 2003. Setting the Record Straight. The Smart Company. Available at http://www.huffingtonpost.com/georgianne-nienaber/report-questions-ngo-acco_b_644009.html.

Bonny Ibhawoh in Daniel A. Bell & Jean-Marc Coicaud, Ethics in Action: The Ethical Challenges of International Human Rights Nongovernmental Organizations, “Human rights INGOs, the North/South Gap: the challenge of normative and empirical learning,”.

Brinkerhoff, J. M. and D. W. Brinkerhoff: 2002, ‘Government-Nonprofit Relation in Comparative Perspective: Evaluation, Themes and New Directions’, Public Administration and Development 22, 3-18.

Burger, R. 2005. What we have learnt from post-1994 innovations in pro-poor service delivery in South Africa: a case study-based analysis. Development Southern Africa 22(4): 483-500.

            Development. Centre for Research on the Economics of Development Working Paper  

Edwards, M. and Hulme, D. 1996. NGO Performance and Accountability. In Beyond the Magic Bullet: NGO Performance and Accountability in the Post-Cold War World. West Hartford: Kumarian Press.

Enrique Peruzotti, Civil Society, Representation and Accountability: Restating Current Debates on the Representativeness and Accountability of Civic Associations, in Lisa Jordan and Peter van Tuijl, Chapter 3, pp, 43-60.

Fama, E and Jensen, M. 1983. Agency Problems and Residual Claims. Journal of Law and Economics, 26: pp. 327 – 350.

Globalization: 21st Century Catalysts for Development. In Everett, S.J., Wu, W. and Yusuf, S. (eds.) Oxford: Oxford University Press.

Hans Antlöv, Rustam Ibrahim and Peter van Tuijl, NGO Governance and Accountability in Indonesia: Challenges in a Newly Democratizing Country in Lisa Jordan and Peter van Tuijl, Chapter 9, pp. 147-163. International Journal of Not-for-Profit Law, Volume 8, Issue 2, January 2006.

Hansmann, H. 1980. The Role of nonprofit enterprise. Yale Law Journal 89: pp. 835    – 901.

Hetty Kovach, Addressing Accountability at the Global Level: The Challenges Facing International NGOs, in Lisa Jordan and Peter van Tuijl, Chapter 12, pp. 195-210.

http://www.ingoaccountabilitycharter.org/about-the-charter/

Hugo Slim, By What Authority? The Legitimacy and Accountability of Non-governmental Organizations, The International Council on Human Rights Policy International Meeting on Global Trends and Human Rights — Before and after September 11(Geneva, January 10-12, 2002).

In Powell, W.W. and Clemens, E.S. (eds.) Private Action and the Public Good. New Haven: Yale University Press.

International Council on Human Rights Policy (ICHRP), pp. 135-139.

James Petras, NGOs: In the Service of Imperialism”, Journal of Contemporary Asia, Vol. 29, Iss. 4, pp. 429-441.

Jassy B. Kwesiga and Harriet Namisi, Issues in Legislation for NGOs in Uganda, in Lisa Jordan and Peter van Tuijl, Chapter 5, pp. 81-92.

Jessica Schultz & Tina Soreide, (2008). Corruption in emergency procurement, published by Blackwell Publishing. Journal compilation; Overseas Development Institute; 32(4): 516-536.

John Bolton, Should we take Global Governance Seriously?, Chicago Journal if International Law, Fall 2000, pp. 205-221.

Jordan and van Tuijl, Rights and Responsibilities in the Political Landscape of NGO Accountability: Introduction and Overview, pp. 3-20. ICHRP, pp. 7—56.

Jordan, Lisa. and Van Tuijl, Peter. (2006). Rights and Responsibilities in the Political Landscape of NGO Accountability.

     

Kenneth Anderson and David Rieff, ‘Global Civil Society’: A Skeptical View, in GLOBAL CIVIL SOCIETY, Helmut Anheier, Marlies Glasius, Mary Kaldor, eds., (Sage Publications 2005).

Kihato, C. and Kabemba, C. 2002. Enhancing policy implementation: Lessons from the Education sector. Centre for Policy Studies Research report 92. Centre for Policy Studies: Johannesburg.

McGann, J. and Johnstone, M. 2006. The Power Shift and the NGO credibility crisis. The International Journal of Not-for-Profit Law, 8 (2): 65–77.Mansuri, G. and Rao, V. 2004. Community-Based and -Driven Development: A Critical Review. World Bank Research Observer, 19(1): 1-39.

Nunnenkamp, Peter, Weingarth, Janina, and Weisser, Johannes, (2008). Is NGO Aid Not So Different After All? Comparing the Allocation of Swiss Aid by Private and Official Donor. Kiel Working Paper No. 1405| March, 2008.

     Olken, B.A. 2005. Monitoring Corruption: Evidence from a field experiment in Indonesia. National Bureau of Economics Research Working Paper 11753, November 2005.

     Olken, B.A. 2006. Corruption Perceptions vs. Corruption Reality. National Bureau of Economics Research Working Paper 12428, August 2006.

     Patricia Armstrong, The Limits and Risks of Regulation: The Case of the World Bank-supported Draft Handbook on Good Practices for Laws Relating to NGOs, in Jordan and van Tuijl, Chapter 4, pp. 61-80.

    Platteau, J-P and Gaspart, F. 2005. Disciplining Local Leaders in Community-.basedRappaport, Roy A. (1999). Rituals and religion in the making of humanity. Cambridge: Cambridge University Press.

    Sarah Okwaare and Jennifer Chapman, Chameleons and Accountability: Linking Learning with Increasing Accountability in ActionAid International Uganda and the Uganda Land Alliance, in Lisa Jordan and Peter van Tuijl, Chapter 10, pp. 167-182.

    Stephanie Strom, “I.R.S. Finds Tax Errors in Reports of Nonprofits,” March 1, 2007.

    Stephen Golub, NGO Accountability and the Philippine Council for NGO Certification: Evolving Roles and Issues, in Lisa Jordan and Peter van Tuijl, Chapter 6, pp. 93-108.

    Stieglitz, J. 1999. On Liberty, the Right to Know, and Public Discourse: The Role of.

   Tendler. J. 2000. Why are Social Funds so Popular? In Local Dynamics in an Era of Thompson, E. (1980). Charity and Nonprofit Organizations. In The Economics of Nonproprietary Organizations. Clarkson, K. and Martin, D. (eds.) Greenwich: JAI Press.Transparency in Public Life, Oxford Amnesty Lecture, Oxford, U.K..

   Veron, R.. Williams, G., Corbridge, S. and Srivastava, M. 2006. Decentralized Corruption or Corrupt Decentralization? Community Monitoring of Poverty-Alleviation Schemes in Eastern India. World Development, 34 11): 1922-1941.

   Weisbrod, B. A.: 1988. The Nonprofit Economy (Harvard University Press, Cambridge MA).

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Edmond R. Gray: In Partial Fulfillment of PhD Public Policy, Ethics and Social Justice Walden University. August 22, 2010. http://remiegray.blogspot.com