In response to the Draft Recommendations to Member States Regarding a Code of Conduct for Non-Profit Organisations to Promote Transparency And Accountability Best Practices — Brussels, 22 July 2005
JLS/D2/DB/NSK D(2005) 8208

The NGO Monitor project welcomes the measures in this draft discussion document prepared by the European Union to insure that funding for non-governmental organizations (NGOs) and non-profit organizations (NPOs) are not used for terrorism, or for groups that support terrorism. As noted in the Draft Recommendations to Member States, there is considerable evidence that "non-profit organisations have been exploited for the financing of terrorism and for other kind of criminal abuse." On this basis, we support measures that will, as indicated, "strengthen donor integrity and confidence, higher standards of transparency and accountability" for non-profit organisations. To this end, we agree with the emphasis that the draft document places on transparency and accountability, to guard against abuse of funding provided by governments to NGOs, and to "help to acquire and maintain public trust and credibility of not for profit work".

We also suggest that the code of conduct for NGOs be extended to include a prohibition on funding to groups that are involved in the incitement that promotes and justifies terrorism. In this context, we note the guidelines adopted by the Ford Foundation following the 2001 Durban Conference (the UN World Conference against Racism, Racial Discrimination, Xenophobia and Related Intolerance, September 2001). These guidelines prohibit funding of "groups that promote or condone bigotry or violence, or that challenge the very existence of legitimate, sovereign states like Israel." (See and

Prof. Gerald M. Steinberg
September 5 2005

EU statement regarding the Draft Recommendations:

Open consultation on the document "Draft Recommendations to Member States regarding a Code of Conduct for Non-profit Organisations to Promote Transparency and Accountability Best Practices"

The Commission would like achieve at an early stage a wide consultation of the actors of the non-profit sector, on the draft recommendations set out in the following preliminary document which does not reflect yet any official position of the European Commission.

The draft recommendations to Member States and the future Code of Conduct for Non-profit Organisations should aim at promoting, on a voluntary basis, transparency and accountability best practices within the non-profit sector with a view to protecting it against the threat of being exploited for the financing of terrorism and for other kind of criminal abuse.
Written contributions should arrive before Monday, 19th September 2005 to the European Commission, DG Justice, Freedom and Security, for the attention of Ms Dora Balazs and Mr Nicholas Kaye. The European Commission reserves its right to publish eventually those contributions.

E-mail comments may be sent to and before Monday, 19th September 2005.

Comments by ordinary post may be sent to the following address, to arrive before Monday, 19th September 2005:
For the attention of Ms Dora Balazs
European Commission
Directorate-General Justice, Freedom and Security
Directorate D: Internal Security and Criminal Justice
Unit D2: Fight against economic, financial and cyber crime
LX 46 3/154 ; B-1049 Brussels, BELGIUM