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September 7, 2018

Shanghai Labor Union Preventing “Enemy Infiltration” along with Managing Foreign NGOs

In an official document dated late July, the Shanghai Federation of Trade Unions, the city’s branch of the country’s official, Party-affiliated trade union, outlined the major themes of its work going forward, including preventing “enemy infiltration” alongside its work in managing foreign NGOs. The document’s articles discussing foreign NGOs strongly suggest that international organizations, at least in the labor sector, are viewed primarily as a national security, rather than a civil society, issue. Though the document is unlikely to have been drafted entirely after recent labor-related protests in Guangdong province, which authorities have blamed in part on foreign NGO involvement, its tone is akin to that of a government-issued “National Security Education Day” cartoon from April that portrayed foreign labor NGOs as seeking to foment unrest in China.

The document, “Shanghai Federation of Trade Unions’ Key Points for Work on Connecting with Society (上海工会社会联络工作要点),” mainly focuses on domestic labor concerns, such as the importance of developing connections with advocacy groups, preventing conflicts in relations with laborers, and dealing with petitioners according to the law. The document’s references to foreign entities, however, underscore the duality in how foreign NGOs are frequently perceived in China. They are, on one hand, subject to a legal mechanism that offers authorities visibility into and oversight of their work; on the other, they are still—and perhaps primarily—perceived as threats to “political security (政治安全)”.

Under a section devoted to “labor union work related to social stability and preventing enemy infiltration,” Article 10 mandates that the Shanghai Federation establish a leading small group to prevent enemy infiltration, participate in an existing citywide mechanism aimed at withstanding foreign hostile forces, and work with other local agencies to manage foreign NGOs. Though the terms “enemy infiltration (防抵渗透)” and “foreign hostile forces (境外敌对势力)” are never used directly in conjunction with the term “foreign NGO (境外非政府组织),” their proximity and inclusion in the same article is telling. Further down in the section, Article 13 offers much more anodyne prescriptions for managing foreign NGOs, including mandating that the Shanghai Federation develop guidelines for serving as a Professional Supervisory Unit. The language in this article is relatively neutral; it is, however, still in the same section that is aimed at preventing “enemy infiltration”.

The document’s preamble suggests that it is a response to central-level policy signals transmitted in the second half of last year. In September 2017, the All-China Federation of Trade Unions (ACFTU) made a trip to Ningxia Autonomous Region, in part to “investigate and guide” work related to “connecting with society (社会联络工作)”. The write-up of this trip makes no mention of foreign groups, enemy infiltration, or political security.

The September trip was followed by a December 2017 conclave in Wuhan, the “ACFTU Conference for Work on Connecting with Society,” headlined by the ACFTU Vice Chair. As described by the ACFTU-run newspaper Workers’ Daily, the conference did not focus on concerns related to foreign organizations or foreign infiltration, but did emphasize official labor unions’ role in safeguarding “political security and social stability”.

Other localities appear to be responding to these policy cues as well. The Jilin City Federation of Trade Unions held a meeting in July focused on “connecting with society” work, and as of April, the Fuzhou City Federation of Trade Unions’ website has a section devoted solely to this work—though neither of them appear to have mentioned security concerns related to foreign groups or entities.

The following is The China NGO Project’s translation of selected articles from the Shanghai Federation document, along with the relevant Chinese-language text.

3. Strengthening conformity and prevention at the source, pragmatically and effectively carry out labor union work related to social stability and preventing enemy infiltration

(10) Actively integrate preventative work mechanisms related to enemy infiltration and strive to ensure political security in the realm of labor relations. Establish the Shanghai Federation of Trade Unions’ Leading Small Group for Work on Preventing Enemy Infiltration and strengthen leadership and coordination related to prevention and resistance work. Vigorously participate in the Citywide Mechanism to Guard against and Withstand Foreign Hostile Forces as established by the municipal Political and Legal Commission; be a member unit of the Foreign NGO Management Office; cooperate fully with public security, state security, civil affairs, and other such agencies and authorities; collectively prevent and withstand foreign forces’ infiltrative and destructive activities. Vigorously participate in handling worker-related mass incidents under the leadership of the Party-state at all levels; prevent hostile forces from infiltrating and destroying the ranks of labor unions, organizations, and workers throughout the city; earnestly safeguard the unity of workers labor unions and organizations. (Responsible department: Labor Relations Work Department; Coordinating department: Shanghai Federation of Trade Unions General Office)

* * *

(13) Formulate management methods for Foreign NGO activities; guide services so that these activities are carried out in accordance with the law and regulations. According to the requirements of the “Law of the People’s Republic of China on Administration of Activities of Overseas Nongovernmental Organizations in the Mainland of China” and the “All-China Federation of Trade Unions Method for Professional Supervision of Foreign NGOs Carrying out Labor Union Research, Exchange, or Cooperative Activities in China (Trial),”1 and in combination with Shanghai’s practical experience, research and formulate “Shanghai Federation of Trade Unions Method for Professional Supervision of Foreign NGOs Carrying out Labor Union Research, Exchange, or Cooperative Activities in Shanghai;” offer directions on service, application, and approval processes; clarify the scope of supervisory work and of activities; fulfill oversight responsibilities; ensure that foreign NGOs in Shanghai carrying out labor union research, exchange, or cooperative activities in accordance with the law and regulations. (Responsible department: Labor Relations Work Department and the Shanghai Federation of Trade Unions General Office)

三、强化整合和源头防范,扎实有效开展工会维稳和防抵渗透工作

(十)主动融入防抵渗透工作机制,努力确保劳动关系领域政治安全。建立上海工会防抵渗透工作领导小组,加强对防范抵御工作的领导和协调;积极参与由市政法委牵头成立的全市境外敌对势力防范抵御工作机制,作为境外非政府组织管理办公室成员单位,会同公安、安全、民政等多部委

通力合作,共同防范抵御境外势力渗透破坏活动;积极参与各级党政主导的职工群体性事件处置,

防止敌对势力对全市工会组织和职工队伍的渗透破坏,切实维护职工队伍和工会组织的团结统一。(责任部门:劳动关系工作部,配合部门:办公室)

* * *

(十三)制定境外非政府组织活动主管办法,指导服务其依法依规开展活动。按照《境外非政府组织境内活动管理法》和《中华全国总工会关于境外非政府组织在中国境内开展工会研究交流合作活动的业务主管办法(试行)》的要求,结合上海实际,研究制定《上海市总工会关于境外非政府组织在上海开展工会研究交流合作活动的业务主管办法》,指导服务申请审批流程、明确业务活动范围、履行监督管理职责,确保境外非政府组织在本市依法依规开展各类工会研究交流合作活动。(责任部门:劳动关系工作部、办公室)


  1. The China NGO Project notes that it has been unable to locate a publicly-available copy of the “All-China Federation of Trade Unions Method for Professional Supervision of Foreign NGOs Carrying out Labor Union Research, Exchange, or Cooperative Activities in China (Trial).”

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Jessica Batke is a ChinaFile Senior Editor. She is an expert on China’s domestic political and social affairs, and served as the State Department’s Bureau of Intelligence and Research Analyst for...