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New Rules for Supplier Bid Challenges Take Effect in China

West, a Thomson business Copyright © 2004
New Rules For Supplier Bid
Challenges Take Effect In China ----- ¶ 38
By Daniel J. Mitterhoff,
Visiting Professor,
Peking University Law School,
Beijing, China
Developments In Export Licensing
For Defense Articles -------------------- ¶ 39
By Linda M. Weinberg and
Lynn M. Van Buren,
Piper Rudnick LLP,
Washington, D.C.
U.S. And EU File WTO Cases
Challenging Subsidies To Boeing
And Airbus ------------------------------ ¶ 40
U.S. Bureau Of Industry And Security
Seeks Comments On Export Control
Procedures ------------------------------- ¶ 41
EC Requests Computer Supply
Contracts Information ----------------- ¶ 42
Large Single Bidders Receive Major
Share Of DOD Procurement
Dollars ----------------------------------- ¶ 43
Congressional Subcommittee Requests
Documents Explaining CPA Actions;
IAMB Reviews DFI Audit Results ---- ¶ 44
Developments In Brief ----------------- ¶ 45
Information and Analysis on Legal Aspects of International Public Procurement
Analysis continues on page 3...
¶ 38
New Rules For Supplier Bid Challenges Take Effect
In China
As of September 11, 2004, new rules governing how the
Chinese government handles complaints by contractors under
China’s nascent government procurement system went into ef-
fect. These rules, entitled Measures for Handling Complaints by
Government Procurement Suppliers (Measures), strive to imple-
ment Chapter Six (Articles 51-58) of China’s 2002 National Gov-
ernment Procurement Law dealing with “Queries and Com-
plaints.” The new Measures were issued by China’s Ministry of
Finance (Year 2004, Order No. 20), the designated oversight
agency for government procurement under the 2002 law.
The new Measures add some important details regarding how
supplier protests will be handled under the 2002 National Gov-
ernment Procurement Law. However, the Measures, like much
of Chinese legislation and regulations, suffer from a general am-
biguity that renders clear guidance problematic. It is not surpris-
ing then that the new Measures raise as many questions as they
answer. There also remains a huge gap between law on the books
and Chinese practice, especially where limiting the exercise of ad-
ministrative power is concerned. Hence, the implementation of
new purchasing procedures are mocked by some as theatric cover
for traditional backroom deals, unchallengeable since bidders fear
that filing a complaint spells doom for their future contracting
opportunities (although cases do exist). Evaluating these systemic
challenges undermining the Chinese legal system is beyond the
purpose of this article. Rather, this article is solely designed to
introduce the reader to some of the peculiarities of the Chinese
public purchasing system, and the proposed changes in China’s
government supplier complaints system inaugurated by the new
implementing regulation.
Problems in Defining Scope of Chinese Government Procure-
ment—For suppliers interested in tapping into the Chinese pub-
lic purchasing market, the first step is to understand the fragmented
nature of the market and the bureaucratic rivalries at work. The
2002 National Government Procurement Law applies to the pur-
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International Government Contractor
chasing of goods, construction, and services by gov-
ernment organs (zhengfu jiguan) as well as social insti-
tutions (shiye danwei) and public organizations (tuanti
zuzhi) that use fiscal funds (caizhengxing zijin). In the
ever-changing Chinese landscape, it is not always clear
what entities qualify as social institutions or public
organizations covered by the law. Similarly, the dis-
tinction between fiscal funds and other publicly-owned
monies creates further confusion, especially given
Chinese difficulty in centralizing its national and lo-
cal budgets.
Chinese state-owned enterprises—the pillars of
China’s socialist economy, many which continue to
benefit from state largesse and privileged market posi-
tions—are not covered by the 2002 National Govern-
ment Procurement law. Their purchasing activities are
regulated elsewhere, with separate regimes governing
their large equipment purchases and construction ac-
tivities. Health care equipment for public hospitals,
entities that arguably qualify as social institutions (shiye
danwei), are still more likely to be purchased by local
health departments under regulations not yet fully in-
tegrated with the new government procurement re-
gime. Military related procurements in China are, not
surprisingly, completely outside the coverage of the
2002 National Government Procurement Law (Article
86). Rules for military procurement may exist, but not
for the eyes of the general public.
The seeming uniformity reflected in the text of
the 2002 National Government Procurement Law,
with its more advanced bid protest mechanism, has
not yet been achieved in practice. The lesson of this
fragmentation is that suppliers must be keenly aware
of who is conducting the purchasing, what is being
purchased, and what type of funds are being used
for the purchase. Each factor may affect a supplier’s
choice of complaint procedures. Suppliers may in fact
need to consult different regulatory regimes to deci-
pher the challenge rules governing a particular pur-
chase, or may be subject to two sets of regulations,
as illustrated by the example below.
China’s 1999 Tender and Bidding Law governs
the procedures for the award of large construction con-
tracts that affect public interest or common security
(guanxi shehui gonggong liyi, gongzhong anquan de
xiangmu) or construction projects using state-owned
invested funds (guoyou zijin touzi), state-financed
projects (guojia rongzi de xiangmu), or loans from for-
eign governments or multilateral lending agencies.
Coverage of this law is at once more limited than the
2002 National Government Procurement Law, in that
it applies to construction only, and also broader, in
that it covers a greater number of entities engaged in
construction (e.g., state-owned enterprises) and a seem-
ingly broader category of funding sources. Generally,
administrative supervision of construction activities
under the 1999 Tendering and Bidding Law is car-
ried out by the State Development and Reform Com-
mission and its local counterparts (for project planning
and approvals) and the Chinese Ministry of Construc-
tion and local construction departments (for project
implementation). However, certain projects subject to
the 1999 Tender and Bidding Law may alternatively
be supervised by China’s Ministry of Transportation/
Communication, Ministry of Railroads or other min-
istries if within their specific zone of jurisdiction. See
e.g., Measures for Tender and Bidding in the Survey,
Design and Construction of Highways (Ministry of
Transportation, August 21, 2001).
The 1999 Tendering and Bidding Law was driven
largely by concerns relating to construction quality
and safety, at the expense of issues relating to moni-
toring the expenditure of government monies, an ob-
vious focus of the Ministry of Finance—the agency
subsequently spearheading the drafting of the 2002
National Government Procurement Law. During the
drafting process for the 2002 National Government
Procurement Law, in an attempt to thwart the ex-
pansion of supervision by the Finance Ministry, of-
ficials from the State Development and Reform Com-
mission and Ministry of Construction argued that
China should exclude construction from coverage of
its government procurement law; an argument that
ultimately failed given its incompatibility with the
international consensus that government procurement
uniformly includes the purchasing of goods, construc-
tion, and services. The passage of the 2002 National
Government Procurement Law thus represents, in
part, a successful effort by the Finance Ministry to
assert control over public construction contracting by
including construction in the definition of what con-
stitutes government procurement.
In the end, however, this proved a limited vic-
tory for the Ministry of Finance. The 2002 National
Government Procurement Law actually intensified
the turf battle by mandating (at Article 4) that gov-
ernment agencies, social institutions, and public or-
ganizations (hereinafter referred to collectively as
“public agencies”) should use the 1999 Tender and
Bidding Law when awarding construction contracts
¶ 38
Vol. 1, No. 5 / October 2004
¶ 38
ing agency has an additional seven working days from
its receipt of the supplier’s inquiry to respond. If the
supplier is unsatisfied by the response of the purchas-
ing agency, or the agency fails to respond within the
time required, the supplier then has an additional 15
working days within which to lodge a complaint with
the “relevant supervisory agency,” (which as noted
above is China’s Ministry of Finance for national level
procurement activities, or the relevant Finance De-
partments at the provincial, municipal, or county
level for local level procurements—hereinafter collec-
tively referred to as the Finance Department). The
Finance Department has 30 working days from re-
ceipt of the supplier’s complaint to issue a decision.
The supplier, thereafter, retains the right to appeal
the decision of the Finance Department, pursuant to
China’s 1999 Administrative Reconsideration Law or
China’s 1989 Administrative Litigation Law.
Once the complaining supplier has submitted his
initial complaint, the Finance Department is required
to make a preliminary review of the complaint within
five working days to make the following negative de-
terminations, if necessary: (1) whether the content
of the complaint does not accord with the regulations
thus requiring the complainant to revise and refile
his complaint; (2) whether the complaint is outside
the jurisdiction of the receiving Finance Department,
and to transfer the complaint to the correct depart-
ment, advising the complainant accordingly; or (3)
whether the complaint does not meet other require-
ments, advising the complainant in writing that the
complaint will not be accepted, and providing a ba-
sis for its refusal. The Measures are sadly silent as to
what type of defect allows revision and re-filing of
the complaint, as compared to those defects that will
condemn that complaint to rejection. Jurisdictional
defects are not fatal to the complaint, requiring in-
stead that the relevant Finance Department transfer
the complaint to the appropriate office. However, it
is unclear how any delays associated with a transfer
affect the duty of the appropriate Finance Depart-
ment to file a timely ruling on the complaint.
If the complaint is not subject to any of the nega-
tive determinations cited above, the complaint is
deemed accepted as of the original date of filing. The
30 working day period within which the Finance
Department must render its decision runs from the
initial date of filing, not from the date the Finance
Department decides it will hear the substance of the
through public bidding. To date then, many local
construction departments continue to assert jurisdic-
tion over construction by both public agencies and
state-owned enterprises. Arguably, suppliers who wish
to protest the award of construction contracts by pub-
lic agencies currently have the option of filing com-
plaints with either the relevant Financial Depart-
ments or Construction Departments (or other
departments depending on the nature of the project).
See Measures For Handling Complaints Related to
Tender and Bidding Activities on Construction
Projects, (State Development and Reform Commis-
sion, July 6, 2004).
One way to make sense of all this confusion is to
view Chinese public purchasing under the following
framework: there is now a core government procure-
ment system—governing purchasing by traditional
public agencies, albeit their scope ill-defined—
surrounded by a broader public procurement regime
regulating a host of other purchasing activities where
public monies are being used and/or the public in-
terest implicated. It seems only direct action by the
Office of the State Council (the Chinese executive)
will ultimately settle the uneasy relationship between
the two regulatory regimes. Until then, suppliers need
to understand the overlapping systems to best deter-
mine whether, in filing its protest, the supplier
should use the new Measures promulgated by the
Ministry of Finance (which implement the 2002
National Government Procurement Law), or resort
to regulations issued by a different Chinese govern-
ment agency under a separate regulatory framework.
Process and Timeliness—China’s 2002 National
Government Procurement Law establishes a manda-
tory administrative process for the filing of supplier
complaints. This process begins at the level of the
procuring agency or any tender agent carrying out
the procurement on behalf of a procuring agency.
Tender agents are enterprises especially licensed to
carry out procurement procedures and may serve as
a respondent in a bid protest in lieu of any end-user
government agency. For ease of discussion, both pro-
curing agencies and tender agents will be referred to
collectively as “purchasing agencies.”
In the event a supplier doubts the fairness or le-
gality of a procurement procedure, that supplier is
required to first file “inquiries” with the purchasing
agency “within seven working days from the date the
supplier knows or should know that its rights or in-
terests are being harmed.” Thereafter, the purchas-
International Government Contractor
¶ 38
The complainant must file copies of the complaint
sufficient in number to be distributed to the purchas-
ing agency and any other suppliers having a relation-
ship to the subject matter of the complaint. The Mea-
sures fail to identify who qualifies as a “supplier having
a relation to the subject matter of the complaint” (tousu
shixiang youguan de gongyingshang), so it is best to as-
sume that, at a minimum, all suppliers participating
in the procurement process should be provided a copy
of the complaint, regardless of their respective chances
of ultimately winning the contract. There are no pro-
visions in the Measures on the effect of failing to no-
tice all “related suppliers.”
The Finance Department only distributes the text
of the complaint to other parties after it determines
to hear the case, delivery of which must be effected
within three working days from its accepting the case
for substantive determination. Therefore, for any ac-
cepted case, the Finance Department must distribute
the complaint within eight working days of its origi-
nal filing. Thereafter, the respondent and other related
parties have an additional five working days from their
individual receipt of the complaint to compile and sub-
mit written support for their respective positions.
Contents of Complaint—The new Measures pre-
scribe both formal and substantive conditions on an
acceptable complaint, which can be found at Articles
8-10. Article 8 mandates that the written complaint
contain (1) the names, addresses, and contact infor-
mation for both the complainant and respondent;
(2) specific allegations with factual support; (3) the
status of any query and any response thereto by the
purchasing agency, with documentary support; and
(4) the date of the complaint. Article 9 approves the
use of legal representatives in the complaint process
(often, but not necessarily, a lawyer) with conditions
for submitting proof of appointment and evidence re-
garding the scope of representation. Article 10 then
adds a series of additional requirements to be satisfied
by the complainant, although the provision is vague
as to whether these matters must be set forth in the
body of the complaint. Article 10 requires that (1) the
complainant be a participating supplier in the relevant
government procurement activity; (2) prior to filing
its complaint, the supplier first institute a query to the
purchasing agency as required by law; (3) the com-
plaint accords with the requirements of the Measures;
(4) the supplier file its complaint within the time re-
quired; (5) the complainant file its complaint with the
Finance Department possessing the necessary jurisdic-
tion; (6) the Finance Department has not previously
ruled upon the subject matter of the complaint; and
(7) the complaint meets any additional conditions es-
tablished by the Finance Department. Complaining
suppliers would be wise to include separate written al-
legations in their complaint indicating that each of the
above cited conditions has been met.
Interested Parties, Evidence, and Hearings
While Chinese government procurement law does not
subscribe to the notion of “interested parties,” as un-
derstood in U.S. bid protest jurisprudence, the Mea-
sures provide a sense, albeit at times confused, of
those parties recognized to have a stake in the out-
come of a bid challenge. As noted, the complainant
must demonstrate its interest by proving it was a par-
ticipant in the procurement process at issue. Further,
the Measures introduce the concept of “suppliers re-
lated to the subject matter of the complaint,” who
are similarly entitled to a copy of the complaint with
an opportunity to submit written argument. The
core complaint process, however, appears limited to
the complainant and the purchasing agency, since
there are no provisions for intervention available to
the “related suppliers.” Moreover, there is no special
recognition of the interests of an original awardee as
is found in U.S. bid protests.
The Measures never introduce the concept of a
formal hearing (tingzhenghui) for the arguing of com-
plaints, but rather awkwardly provide that the Fi-
nance Department can, if necessary, “investigate to
collect evidence and [even] organize to solicit evidence
from both the complainant and respondent in the
presence of each other.” Thus, it is unclear whether
some sort of an administrative hearing process will
grow out of the new Measures. (Note that U.S. bid
protest practice before the Office of the U.S. Comp-
troller General demonstrates that a hearing is not a
prerequisite to a responsive protest system that dis-
penses justice and is acceptable to both contractors
and the government.) It should be expected that most
protest evaluations by the Finance Department will
be conducted solely on the papers.
If a hearing is nevertheless convened, it will be lim-
ited to attendance by the complaining contractor and
the responding purchaser only. The elusive class of “re-
lated suppliers” is not envisioned to be part of the “or-
ganized” collection of evidence, but, again, merely pro-
vides the opportunity to be heard in writing. In similar
spirit, the Measures only specify sanctions for the fail-
ure of the complaining supplier or responding govern-
Vol. 1, No. 5 / October 2004
¶ 38
ment agency to cooperate in the Finance Department’s
investigation, and are silent on penalties for the fail-
ure of third parties to cooperate. Complaining sup-
pliers, who do not cooperate, risk having their com-
plaint dismissed, while non-cooperating government
purchasers, who fail to provide relevant information
and documentation, risk having the allegations of a
supplier’s complaint admitted as true. From an evi-
dentiary standpoint, the threat against the procuring
agency—that without cooperating, it will forfeit its
right to contest the complaint—is compelling, since
in China, the absence of respect for the judiciary, the
dearth of discovery tools, and the current lack of Free-
dom of Information Act type legislation renders most
government procurement information under the strong
arm of the purchasing agency.
Decision, Remedy, and Penalties—The Measures
provide three bases for the Finance Department to
enter a decision on a supplier’s complaint: (1) if the
supplier withdraws his complaint, the Finance De-
partment can terminate the process; (2) if the com-
plaint lacks factual support, the Department can re-
ject the complaint; or (3) if the allegations of the
complaint are found to be true, then the Finance
Department should deal with the case per the ap-
plicable provisions of the Measures.
The remedies provisions of the Measures are per-
haps the most interesting, because they differentiate,
with some confusion, between (a) cases where the so-
licitation documents merely suffer from a “clear slant
or discrimination problem” and cause damage, or
may cause damage to the complainant and other sup-
pliers; and (b) those cases where the result of the pro-
curement process and corresponding award result
from interference or illegal activities. These remedial
measures, contained in Articles 18 and 19, respec-
tively, read initially as a distinction between pre-
award and post-award disputes, but this distinction
gets blurred when reviewing the remedies made avail-
able under each circumstance. Rather, it appears that
the Measures are differentiating between innocent,
yet incompetent, drafting of solicitation documents
(where the intent to affirmatively undermine com-
petition policy is absent), and volitional acts by par-
ties or individuals that negatively impact on contract
award and impair the rights of honest suppliers. Ei-
ther case gives rise to relief for the complaining sup-
plier, but the remedies differ.
When the investigation by the Finance Depart-
ment uncovers only that the tender documents are
slanted or discriminatory, the following rulings may
be made: (1) when the procurement process is not yet
completed, order the revision of the solicitation docu-
ments, and restart the solicitation according to the re-
vised solicitation documents; (2) if the procurement
procedure is already concluded but the procurement
contract has not yet been signed, then determine the
process to be illegal and order resolicitation; or (3) if
the procurement process is already completed and the
procurement contract is already signed, then determine
the process illegal, and order the respondent to bear
corresponding liability to compensate the supplier ac-
cording to relevant legal stipulations. At present, there
are no “relevant legal stipulations” that indicate
whether an aggrieved supplier who wins its protest is
limited to collecting merely bid preparation/protest
costs or will be entitled to greater compensation such
as contract expectation damages.
The first remedies provision above (Article 18)
reflects something greater than just a pre-award pro-
test, because under item three, a successful protest
is not grounds to invalidate an already signed pro-
curement contract, but only grounds for an award
of damages. (If there is a signed contract already, the
protest is obviously post-award.) Compare this to the
second remedies provision described below (Article
19), which allows for invalidation of signed, but not
yet performed contracts.
When the investigation by the Finance Depart-
ment demonstrates interference in the procurement
process or illegal activities, then the remedies avail-
able are (1) if the procurement contract is not yet
signed, then determine, based on the circumstances,
whether the whole procurement process or just part
thereof is illegal, and order resolicitation; (2) if the
procurement contract is already signed, but not yet
performed, then cancel the contract and order
resolicitation; or (3) if the procurement contract is
already performed, determine that the procurement
activity is illegal, and order all those responsible to
compensate for the damages to the procuring agency
or the complaining supplier. Again, the damage cal-
culation remains woefully indeterminate.
The remedy provisions reflect a policy that pro-
curement contracts will only be cancelled if they re-
sult from illegal activities by individuals associated
with the process, and only if the contracts have not
yet been performed. (The impact of nominal or par-
tial performance by an original awardee is not differ-
entiated.) In cases where the contract performance has
International Government Contractor
¶ 38
already commenced, China is opting to compensate
contractors solely with money damages, although the
sufficiency of these damages remains suspect.
The Finance Department is required to issue a
signed written decision, which shall include the follow-
ing: the names and address of the complainant and re-
spondent; the appointment of representatives, includ-
ing each representative’s name, profession, address, and
contact information; the specific contents of the deci-
sion, including factual support and legal bases; advice
to the complainant of his rights to apply for adminis-
trative reconsideration or file for administrative litiga-
tion; and the date of the decision. Importantly, the Fi-
nance Department must provide written notice of the
result of its handling of the complaint to all interested
parties, and must publicize the result in a medium des-
ignated by Finance Departments at the provincial level
or above. Indications are, however, that the Finance
Department need only publicize the decision (e.g. sus-
taining or denying the protest), not the full written ad-
judication. China’s penchant for maintaining all gov-
ernment information as internal, combined with its civil
law tradition of not recognizing case precedents, bodes
ill for the development of a body of case decisions, which
could ultimately provide binding guidance to under-
standing the application of China’s government pro-
curement law and regulations.
Stay of Procurement Proceedings—Like the Na-
tional Government Procurement Law, the new Mea-
sures confirm that the Finance Department has the
discretion to temporarily suspend the procurement
process, but for no longer than 30 days. There is no
automatic stay triggered by the filing of a complaint,
only a stay that may be affirmatively ordered by the
Finance Department while it considers the case. No
standards for applying a stay are set, leaving full dis-
cretion to the Finance Department. Any stay order
takes effect only when in the purchasing agency’s
hand, creating an incentive for the purchaser to quickly
render an award, and institute performance of the pro-
curement contract, as to undermine a complainant’s
ability to later overturn the contract award.
There is no express prohibition against the con-
tractor petitioning for a stay in its written complaint,
but the 2002 Government Procurement Law and sub-
sequent Measures are written to suggest the stay is a
matter for the Finance Department, not the parties.
When eventually notified of a stay order, the Measures
admonish the purchasing agency to immediately cease
the relevant procurement activity and not proceed
again until the 30 day stay period expires, or when
the Finance Department otherwise indicates that the
agency may resume its purchase, whichever is shorter.
Protecting Supplier Information—The 2002 Na-
tional Government Procurement law recognizes the need
to protect a supplier’s confidential information and trade
secrets, but its mechanisms to prevent illegal disclosure
are basically non-existent. The Measures similarly miss
a crucial opportunity to enact specific procedures for
ensuring the confidentiality of supplier information by
merely stating: “As to individual private matters and
business secrets learned during the process of handling
a complaint, the Finance Department and other per-
sons with knowledge must bear a duty to maintain se-
crets.” This bare policy assertion offers little comfort to
a government contractor operating in a country known
for its counterfeiting prowess.
Administrative Sanctions and Other Liability
Chinese statutes often reflect the penchant to include
provisions for administrative and criminal penalties,
no matter the subject of the legislation or regulation.
The Measures are no exception and encourage the
Finance Department to issue penalties against any-
one (purchasing personnel, evaluators, suppliers)
found, by virtue of the Finance Department’s inves-
tigation of complaints, to have engaged in illegal ac-
tivity. In cases where the appropriate penalty is be-
yond the power of the Finance Department to issue,
the Finance Department is instructed to transfer the
matter to departments with the requisite authority.
Debarment awaits those suppliers that file three or
more frivolous complaints within a year, or fabricate
facts or provide forged documents in the complaint
process. Purchasers that damage third parties should
be ready to bear liability, and those Finance Depart-
ment personnel handling supplier complaints should
receive administrative punishment in instances where
they misuse their authority, are derelict in their du-
ties, or engage in self-dealing. Criminal liability
should also attach to such personnel when appropri-
ate. The Measures offer no guidelines (other than
supplier blacklisting) for the specific punishments
that await those who run afoul of its provisions.
Party at Fault Pays Costs—While the Finance
Department is prohibited from taking fees to handle
complaints, the party found to be at fault, (which
may in some cases be both parties), is responsible for
paying any calculable costs associated with the pro-
cedure. It is not clear whether this is a loser pays rule
or something different, but a similar provision was
Vol. 1, No. 5 / October 2004
¶ 38
contained in earlier drafts of the 2002 Government
Procurement Law, but later omitted from the final
text. It may reflect more of an administrative con-
cern as to how to fund the complaint process, than
a policy of sanctioning the unsuccessful party. Nev-
ertheless, in a country where “taking on city hall” re-
mains fraught with risk and the prospects of succeed-
ing against the Chinese government in litigation
uncertain at best, the chilling effect of this type of
rule on suppliers already cautious about filing a com-
plaint should not be underestimated.
Conclusion—Hope remains that the new Measures
for Handling Complaints by Government Procurement
Suppliers reflect one more step in the Chinese jour-
ney to establish a government procurement system free
of corruption and local protectionism, where all sup-
pliers may compete equally. If contractors in the
Chinese market prove brave enough to challenge gov-
ernment contracting decisions, and the Finance De-
partment treats all complaints thoroughly and fairly,
we might just witness such a marvelous result.
This analysis was written for INTERNATIONAL GOVERN-
MENT CONTRACTOR by Daniel J. Mitterhoff. Mr.
Mitterhoff is a visiting professor of Comparative Gov-
ernment Procurement Law at Peking University Law
School in Beijing, China, where he is working on the
establishment of a Research Center for Government
Procurement and Public Construction Law. He also
serves as President of the China-Mekong Law Cen-
ter, a non-profit corporation dedicated to, among
other things, improving legal education in Asia.
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