NGO Law Monitor: Cambodia

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Last updated 8 September 2013

Introduction

Cambodia is an example of a post-conflict society in which traditional forms of civil society organizations (CSOs) were devastated and then re-emerged in new forms as part of the reconstruction process. CSOs include Buddhist institutions, trade unions, media associations and non-governmental organizations (NGOs). In 1989 the first humanitarian international NGOs (INGOs) arrived and the establishment of local NGOs soon followed.

The Royal Government of Cambodia (RCG) and development partners recognize that NGOs and INGOs have made an important contribution to rehabilitation, reconstruction and development for the past 30 years. NGOs are viewed as important partners in the delivery of basic social services. Formally the RCG has a number of mechanisms that involve NGOs in national development strategy formulation and policy implementation and dialogue. In practice, however, NGOs have limited influence on government strategy and policy and limited space for dialogue.

Beyond the service provision sphere, the environment for NGOs is very different. NGOs involved in advocacy, legal rights and human rights are seen by the RCG as unwanted opposition and the environment for their activity is restrictive. The power of the Cambodian People’s Party (CPP) is increasing and the Cambodian State is becoming increasingly authoritarian. There is widespread concern from NGOs and other stakeholders on key issues relating to the increased violation of land rights and the restriction of fundamental human rights, such as the freedom of expression and freedom of assembly. Human rights defenders are continually the target of threats and attacks. The recent UN UPR submissions and outcomes document this. (December 2009 www.upr-info.org/-Cambodia-.html).

Currently the legal framework in Cambodia is governed by the Constitution, but there are no specific implementing laws. There are different registration requirements for INGOs and NGOs. INGOs are required to conclude a Memorandum of Understanding with the Ministry of Foreign Affairs and an administrative order requires local NGOs to register with the Ministry of the Interior. The current legal framework is open to discretion and its implementation saddled by a weak understanding of the concept of civil society. There is no effective judiciary or effective rule of law in Cambodia. The RCG has recently taken the unprecedented step of including civil society leaders within the scope of the newly enacted Anti-Corruption Law, by requiring them to disclose assets.

On December 15, 2010, a draft Law on NGOs/Associations, prepared by an inter-ministerial committee, was made public. Following a public consultation meeting in January 2011 and a critical advocacy campaign led by Cambodian organizations, the Government of Cambodia released a second, revised draft Law in late March and a third version in July. The Ministry of Interior is reportedly now working on a fourth version of the draft Law.

At a Glance

Organizational Forms	NGOs and associations (although there is no clear definition of these organizational forms provided in the law)
Registration Body	The Ministry of Interior is responsible for local NGOs and associations. The Ministry of Foreign Affairs and International Cooperation is responsible for international NGOs.
Approximate Number	Approximately 3,492 registered NGOs and associations. Of this number, it is estimated that approximately 1,350 organizations remain active.
Barriers to Entry	Registration is mandatory for all NGOs and associations. The procedural requirements for the registration of international NGOs are complex and burdensome. Procedural safeguards regarding registration are lacking, with the Government having full discretion to deny registration.
Barriers to Activities	Advance notification to the state or governmental approval is required for certain activities. International NGOs are subject to reporting requirements on a quarterly basis. The Government of Cambodia is increasingly applying pressure and intimidation on certain NGOs and the communities in which they work.
Barriers to Speech and/or Advocacy	Laws criminalizing defamation, disinformation, and incitement.
Barriers to International Contact	No barriers
Barriers to Resources	No barriers

Key Indicators

Population	14, 494, 293
Capital	Phnom Penh
Type of Government	Multiparty democracy under a constitutional monarchy
Life Expectancy at Birth	Male: 60.03 years Female: 64.27 years (2009 est.)
Literacy Rate	Male: 84.7% Female: 64.1%
Religious Groups	Buddhist: 96.4%; Muslim: 2.1%; other: 1.3%; unspecified: 0.2% (1998 census).
Ethnic Groups	Ethnic Groups Khmer: 90%; Vietnamese: 5%; Chinese: 1%; other:4%.
GDP per capita	$1,900 (2009 est.)

Source: The World Factbook. Washington, DC: Central Intelligence Agency, 2009.

International Rankings

Ranking Body	Rank	Ranking Scale (best – worst possible)
UN Human Development Index	139 (2011)	1 – 182
World Bank Rule of Law Index	12.8 (2010)	100 – 0
World Bank Voice & Accountability Index	24.6 (2010)	100 – 0
Transparency International	(2011)	1 – 180
Freedom House: Freedom in the World	Status: Not Free Political Rights: 6 Civil Liberties:5	Free/Partly Free/Not Free 1 – 7 1 – 7
Foreign Policy: Failed States Index	37 (2012)	177 – 1

Legal Snapshot

International and Regional Human Rights Agreements

Key International Agreements	Ratification*	Year
International Covenant on Civil and Political Rights (ICCPR)	Yes	19992
Optional Protocol to ICCPR (ICCPR-OP1)	Yes	2004
International Covenant on Economic, Social, and Cultural Rights (ICESCR)	Yes	1992
Optional Protocol to ICESCR (OP-ICESCR)	No	--
International Convention on the Elimination of All Forms of Racial Discrimination (ICERD)	Yes	1983
Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW)	Yes	1992
Optional Protocol to the Convention on the Elimination of Discrimination Against Women	No	2001
Convention on the Rights of the Child (CRC)	Yes	1992
International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families (ICRMW)	Yes	2004
Convention on the Rights of Persons with Disabilities (CRPD)	Yes	2007

* Category includes ratification, accession, or succession to the treaty

Constitutional Framework

The Cambodian Constitution was adopted by the Constitutional Assembly in Phnom Penh on 21 September 1993.

Relevant Constitutional provisions include:

Article 41
Khmer citizens shall have the freedom of expression, press, publication and assembly. No one shall exercise this right to infringe upon the rights of others, to affect the good traditions of the society, to violate public law and order and national security. The regime of the media shall be determined by law.

Article 42
Khmer citizens shall have the right to establish associations and political parties. These rights shall be determined by law. Khmer citizens may take part in mass organisations for the mutual benefit to protect national achievement and social order.

National Laws and Regulations Affecting Sector

Relevant laws relating to civil society in Cambodia include:

Law on Taxation (2004);
Penal Code (new 2009 Code pending enactment);
Civil Code (2007);
Counter-terrorism Law (2007);
Peaceful Demonstrations Law (2009) (pending enactment); and
Anti-corruption Law (2010) (approved by the Senate and pending promulgation by the King).

Legal personality: The Civil Code, adopted in 2007, recognizes registered NGOs as legal entities and makes them subject to its provisions.

Registration: The procedure for registration, governed by administrative order or prakas, is a reasonably simple and straightforward process for local NGOs. INGOs must conclude a Memorandum of Understanding with the Government, which is a more complex process.

Criminal responsibility: Members of NGOs are subject to the UNTAC Penal Code, pending enactment of the new Penal Code. The new draft Penal Code – currently before the National Assembly - will regulate a number of criminal activities, including such crimes as fraud, embezzlement, corruption, terrorism, etc. The 2007 Counter-terrorism Law has detailed provisions relating to the question of financing of and material assistance to terrorism.

Taxation: According to the 1997 Tax Law, NGOs do not pay taxes on their income, if they are organizations with either religious, charitable, scientific, literary, or educational purposes; (Article 9 of the Tax law).

Financial transparency: NGOs are accountable to the public that they aim to serve, and to their donors through financial audits. To guard against financial mismanagement and corruption, the recently enacted Anti-corruption Law will be applicable to everyone, including public authorities, civil society actors and private enterprises.

Self-regulatory mechanism: NGOs in Cambodia have established a Voluntary Certification Scheme. To be certified by this system, NGOs subject themselves to a Code of Ethical Principles. The system is recognized at international and national levels as an effective way to build accountability and transparency.

Pending NGO Legislative / Regulatory Initiatives

On December 12, the Royal Government of Cambodia released the fourth draft version of the Law on Associations and NGOs. A consultation meeting between the Government and a select group of civil society organizations was held on December 19. At the consultation meeting, Deputy Prime Minister Sar Kheng made clear that this was not the end of the consultation process, and the Ministry of Interior invited written comments on the draft Law. ICNL prepared an analysis of the fourth draft Law, which is available here. Cambodian CSOs prepared and submitted a consolidated analysis on the draft Law, which was submitted to the Ministry of Interior on December 23. Subsequently, on December 28, Prime Minister Hun Sen stated that the Law on Associations and NGOs need not be enacted quickly and that consultations with CSOs can continue until 2014. In April 2012, contacts at the Ministry of Interior informally reported that although the draft Law is officially on hold, the Ministry is continuing to work on it; there is no further information available about the content or timing of these drafting efforts.

The legislative history leading up to the release of the most recent draft Law is as follows:

In August 2010, a draft Law on NGOs/Associations was reportedly completed by an inter-ministerial committee. The Ministry of Interior issued an open call for support for a national consultation on the draft Law. In response, NGO representatives sought assurances that the draft Law be made available to the NGO community to allow for adequate review of the draft law and time for regional consultations at least one month prior to the planned national consultation.
The first version of the draft Law was released on December 15, 2010. A public consultation workshop on the draft Law was hosted by the Ministry of Interior on January 10, 2011. More than 200 national and international NGO representatives attended. After the workshop, local NGOs submitted suggested revisions of the law to the government.
A second, revised version of the draft Law was released on March 24, 2011. Reaction to the revised draft has highly critical, as many of the problematic provisions from the first draft remained and new concerns arose. There was, however, no second consultation meeting.
The third draft was released on July 29, 2011. Reportedly, the draft Law moved from the Prime Minister’s Office to an inter-ministerial working group at the Council of Ministers and was approved by the Council of Ministers, but not forwarded to the National Assembly.

Legal Analysis

Organizational Forms

Cambodian law currently lacks a clear definition of “NGO”.

The Ministry of Interior (MoI) registers local NGOs and associations. There is no definition for local NGOs and Associations in the administrative order or parka relating to NGO registration.

The Ministry of Foreign Affairs and International Co-operation agrees to a Memorandum of Understanding (MoU) with INGOs; there is also a requirement for INGOs to sign separate MoUs with the various Ministries that relate to the INGO’s sphere of work. The definition of an NGO, as provided in the annex of the MoU document for INGOs is as follows:

The Non-governmental Organization: may be defined as the Organization which has been established by an individual or by any group of individuals to carry out humanitarian activities and non-profit, social development for social welfare and public benefit. The NGO refrains from any activities in support of any Political Parties.

According to recent figures from the MoI, there are 2,465 registered NGOs and associations: 1,034 associations and 1,431 NGOs. Accurate data is not available but many of these NGOs and associations are believed to be inactive. It is estimated that there are approximately 300 INGOs, but again many of these are believed to be inactive.

Public Benefit Status

Cambodian law does not provide for a special public benefit status.

According to the 1997 Tax Law, NGOs do not pay taxes on their income, if they are organizations with either religious, charitable, scientific, literary, or educational purposes; (Article 9 of the Tax law).

Barriers to Entry

The legal framework in Cambodia includes at least three barriers to the formation of organizations.

First, registration for all NGOs and associations is required. Unregistered organizations can be closed down.

Second, the procedural requirements for the registration of INGOs are complex and burdensome. The process involves concluding an initial Memorandum of Understanding (MoU) with the Ministry of Foreign Affairs (MoFA) and subsequently with each separate ministry that the INGO’s activity relates to. At the close of this section are listed the procedural requirements for both local NGOs and INGOs seeking to operate in Cambodia.

Third, the legal framework does not provide procedural safeguards that ensure a professional, apolitical, uniform registration process. For example, there is no fixed time period for government review of registration applications. The Government has discretion to deny registration; there are no standards provided to guide the exercise of its discretion. There is no clear right to appeal.

Documentation requirements at the time of registration are listed here.

For local NGO and associations, registration with the MoI requires the applicant organization to provide:

Five copies of the application form for registration, with signatures (confirmed by the commune and district on the back of the form);
Two copies of permission letters, issued by the municipality, relating to the location of the office of the local organization;
The curriculum vitae of at least three Cambodian founders, including the director, the administrator and the treasurer (5 copies each), and 4x6 photographs (attached with copied Khmer ID card or birth certificate or equivalent documentation);
Five copies of the statute of the local organization, with signatures of the director; and
Five copies of the organizational structure, with signatures of the director.

Additional requirements include maps of office locations, photos of buildings and copies of lease agreements.

There are slightly relaxed requirements for organizations with offices outside Phnom Penh.

For INGOs, registration with the MoFA/IC requires the applicant organization to provide:

The letter of registration recognized by the authority of the country where the headquarters of the INGO is located;
The project plan and budget (to be implemented in Cambodia), as approved by the Board of Directors of the INGO.
The letter from the headquarters of the INGO, giving authority to its organizational representative in Cambodia to sign the MoU and represent the INGO in Cambodia;
The list of foreign staff persons, including the nationality, passport number, role, address in Cambodia and accompanying employment contract;
The list of Cambodian staff persons, including the worker ID Card or any similar document and accompanying employment contract;
The address of the office in Cambodia, with accompanying lease agreement;
A bank Statement; and
Support letters from the line ministries.

INGOs are required to renew the MoU every 3 years.

Barriers to Operational Activity

Advance notification and approval.

Regarding Local NGOs: The Ministry of Interior (MoI) has issued guidelines relating to activity notification. If local NGOs are conducting activity in a province other than where they are registered, then the local authority needs to be informed five days in advance. In some provinces the guidelines are interpreted as directives that mean that approval for activity is required by provincial authorities. \
Regarding INGOs: Article 2 of the Memorandum of Understanding (MoU) requires INGOs “to carry out its humanitarian projects in other locations or provincial cities upon due approval of relevant governmental authorities based on government priorities.” Article 18 requires INGOs to work “in close consultation with counterpart government institutions and local authorities to implement the approved projects or programs.” In particular, INGOs must inform counterparts when assigning a consultant to work in the field or requesting visa extension for an expert to complete the job.

Political activity. Currently NGOs and INGOS are required “to refrain from activity in support of Political Parties.” There is concern that political activity will be subject to broader restrictions under any new legislation.

Reporting requirements. INGOs are required to provide both quarterly reports and annual reports.

Government harassment. There is growing concern that the RCG is increasingly applying pressure and intimidation on people in the communities NGOs work with and also directly on NGOs and their staff. This is particularly evident where NGOs are conducting activities relating to the protection of land rights of the poorest communities in urban and rural areas, natural resources management, and the promotion of the freedoms of expression, assembly and association. In such spheres of activity, the Government has acted to arbitrarily restrict the freedom of movement and the freedom of assembly and expression. Examples of state action include:

Permission needed for community members to travel (even between villages);
Meetings monitored by police and state authorities;
An increase in the frequency of arrests, charges and detention of NGO representatives and community members;
Threats against communities that engage with NGOs;
Photographing meeting participants;
Requesting names/contacts of meeting participants; and
Police disturbances of activities in meetings.

Barriers to Speech / Advocacy

There are a number of legal avenues used by the courts to curtail the freedom of expression in the country, namely through charges of defamation, disinformation and incitement. [These legal avenues are found within the UNTAC Code (Provisions relating to the Judiciary and Criminal Law and Procedure Applicable in Cambodia during the Transitional Period).] According to one NGO representative: “The ruling party has embarked on a campaign to crack down on freedom of expression and suppress the parliamentary opposition, the news media, the legal profession and, to some extent, NGOs. At the center of the campaign is the government’s misuse of the courts to file unjustified criminal charges against its critics.” [1]

According to an October 2009 statement made by the Special Rapporteur on Human Rights in Cambodia to the Human Rights Council, the defamation laws of Cambodia have gone beyond what is a permitted level of restriction on freedom of expression under the 1966 International Covenant on Civil and Political Rights to which Cambodia is a party. A series of defamation and disinformation suits were brought primarily by high-ranking government officials against opposition journalists and editors, opposition Parliamentarians and human rights defenders in 2009.[2]

[1] Tom Lantos Human Rights Commission Hearing on Cambodia, September 10, 2009.Testimony by Dr. Chhiv Kek Pung, President & Founder, Cambodian League for the Promotion & Defense of Human Rights (LICADHO).

[2] See statement of OHCHR Cambodia Office of 5 August 2009

Barriers to International Contact

There are no legal barriers limiting international contact or communication.

Barriers to Resources

There are no legal restrictions inhibiting either domestic or foreign funding. In terms of spending, there is a guideline limiting the amount spent for administration to a maximum of 25% of funding.

Reports

UN Universal Periodic Review Reports	Universal Periodic Review: Cambodia
Reports of UN Special Rapporteurs	Cambodia
USIG (United States International Grantmaking) Country Notes	Not available
U.S. State Department	2010 Country Reports on Human Rights Practices: Cambodia Advancing Freedom and Democracy Reports, 2010: Cambodia
Failed States Index Reports	2012 Foreign Policy Failed States Index
IMF Country Reports	Cambodia and the IMF
International Commission of Jurists	Not available
International Center for Not-for-Profit Law Online Library	Not available

News and Additional Resources

While we aim to maintain information that is as current as possible, we realize that situations can rapidly change. If you are aware of any additional information or inaccuracies on this page, please keep us informed; write to ICNL at ngomonitor@icnl.org.

General News

Cambodian Officials Ask Opposition to Downsize Election Protest Rallies (September 2013)
Officials in Cambodia’s capital ordered the country’s main opposition party to scale back plans for mass demonstrations aimed at backing demands for an independent probe into election fraud charges. The Cambodia National Rescue Party (CNRP), led by Sam Rainsy, has vowed to hold a 20,000-strong protest in Phnom Penh for three consecutive days beginning September 15 after the authorities rejected calls to investigate irregularities in the July 28 elections. The country’s National Election Committee (NEC), which supervised the polls, confirmed over the weekend that Prime Minister Hun Sen's ruling Cambodian People’s Party (CPP) had won the hotly-contested vote, prompting warnings from the opposition that it would rally against the result.

Resistance and Solidarity: Cambodian CSOs confront a repressive draft law on associations and NGOs (May 2013)
At the end of December 2011, in a surprise move, Cambodia’s Prime Minister, Hun Sen, agreed to delay by two years the adoption of a controversial proposed law governing the activities of civil society and non-governmental organisations (NGOs). Cambodian civil society organizations (CSOs) welcomed the commitment by the Prime Minister to give more time for the government and Cambodian civil society community to come to an agreement on outstanding issues in the fourth version of this draft law, published by the government a few weeks earlier. In 2013, the draft law remains pending, though other obstacles in the CSO legal framework remain.

Human Rights Group Shortlists Sonando for Award (January 2013)
A Dublin-based human rights group has named jailed Beehive Radio station owner Mam Sonando one of a half-dozen finalists from around the world for its annual award for rights defenders. Mr. Sonando, who owns one of the country’s few independent radio stations and heads an NGO that teaches rural communities about their human and voting rights, was convicted of fomenting a rural secessionist movement in November and sentenced to 20 years in jail. Dozens of local and international rights groups have denounced the conviction—after a show trial that offered no evidence linking Mr. Sonando to the alleged insurrection—as a political move to silence a popular government critic.

Call for Cambodia to respect freedom of assembly ahead of ASEAN Summit (November 2012)
FIDH calls on Cambodia to preempt disrupting civil society events and restricting freedom of expression and assembly ahead of ASEAN Summit. Read the Statement here.

Obama should publicly denounce rights abuses (November 2012)
US President Barack Obama should publicly express grave concern about Cambodia’s long deteriorating human rights situation while in Phnom Penh for the US-ASEAN and East Asia summits on November 19 and 20, 2012, Human Rights Watch said today. Hun Sen, Asia’s longest serving head of government, has ruled Cambodia for over 27 years and has publicly vowed to remain in power for another 30.

UN labour agency names five countries where ‘serious and urgent’ labour-rights cases need attention (November 2012)
A key rights committee of the United Nations labour agency identified five countries where it says worker-rights violations – some involving murder – represent the “most serious and urgent cases” among 32 countries examined at its meeting. Argentina, Cambodia, Ethiopia, Fiji and Peru were singled out by the Committee on Freedom of Association of the UN International Labour Organization (ILO) after Committee members reviewed cases involving rights to organize, negotiate through collective bargaining and engage in social dialogue.

Cambodian NGO workers, villagers face intimidation (November 2012)
During a mission to the provinces to collect information regarding land conflicts, the Land Reform Project Team of the Cambodian Center for Human Rights ("CCHR"), was faced with interference and disruption to its work in Thlao Village, Banteay Chhmar Commune, Thma Pouk District, Banteay Mean Chey Province on 29, 30 and 31 October 2012. The disruption of the work of NGOs is a growing trend and amounts to the violation of freedoms of expression, information, assembly and association, all of which must be upheld under the United Nations International Covenant on Civil and Political Rights, ratified by Cambodia in 1992, and also protected under the Constitution of the Kingdom of Cambodia.

Cambodia disrupting civil society events and restricting freedom of assembly ahead of ASEAN Summit (November 2012)
Civil society organizations strongly urge the Cambodian authorities to immediately end the ongoing intimidation, threats and harassment of organizers, venue owners and participants involved in civil society events in Cambodia’s capital, Phnom Penh ahead of the 21st Association of Southeast Asian Nations (ASEAN) Summit and the 7th East Asia Summit.

Cancel convictions of critics and protesters (October 2012)
Cambodia’s donors, including the United States, European Union, Japan, and the United Nations, should insist on the immediate release of prominent critic of the government Mom Sonando and other activists convicted on trumped-up charges. On October 1, 2012, a Phnom Penh criminal court sentenced Sonando to 20 years in prison on trumped up charges of participating in a purported “secession” movement, while three local activists were sentenced to terms of 15 to 30 years and three others to terms of up to 5 years.

“A Robust Civil Society is Necessary for Cambodia’s Advancement” (September 2012)
Read the Statement that a member of the US Delegation to the UN Human Rights Council, Eric N. Richardson, made at the 21st session of the UN Human Rights Council in Geneva.

NGOs push donors on rights (September 2012)
More than 100 NGOs gathered in Cambodia’s capital Phnom Penh calling on donor countries to make aid conditional on government reforms for a more transparent electoral process and efficient judicial system.

Activists detained on dubious charges (September 2012)
Yorm Bopha and Tim Sakmony were arrested on September 4 and 5, respectively, on dubious charges. Yorm Bopha, for example, long prominent in protests against forced evictions of residents from the Boeung Kak area of Phnom Penh, was detained for allegedly assaulting a person who was suspected of stealing. In view of the Cambodian authorities’ established record of abuse of the law and misuse of the courts to persecute political opponents, social activists and human rights defenders for their legitimate exercise of basic human rights, CSOs are concerned that the actions against Bopha and Sakmony were very likely motivated by their involvement in protests and campaigns on behalf of the land and housing rights of local communities.

Radio station owner and NGO leader is prisoner of conscience (July 2012)
Mam Sonando, aged 71, was arrested at his home in Phnom Penh on July 15. He was charged with offences against the state and, if convicted, faces a long prison sentence. Mam Sonando owns one of Cambodia’s few independent radio stations, Beehive Radio. He is also the head of a popular NGO that promotes human rights and democracy, the Association of Democrats. The charges against Mam Sonando stem from a speech the Prime Minister delivered on June 26 accusing the radio station and members of the Association of Democrats of being behind a plot for a village in Kratie province to secede from Cambodia and become an independent state. The Cambodian authorities used this as a pretext for the violent eviction in mid-May of around 1,000 families living in that village, during which the security forces shot dead a 14-year-old girl. The real reasons for Mam Sonando’s arrest seem to be the popularity of the Association of Democrats and his radio station.

U.S. Secretary of State Clinton prods Cambodia on jailed protestors (June 2012)
In her talks with Foreign Minister Hor Namhong in Washington on Tuesday, Secretary of State Clinton said the United States was concerned about the Cambodian government's handling of the land protests which led to the jailing of 13 women for between one year and two and a half years. The protests were over a longstanding dispute between tens of thousands of residents of capital Phnom Penh’s Boeung Kak Lake district who were evicted from their homes, or are in risk of losing them, and developers looking to turn the area into a luxury residential and shopping center. The women had been jailed for disputing authority and trespassing on the development site.

Cambodian government sparks outrage by picking NGO representatives for ASEAN Summit (March 2012)
The Cambodian government chose representatives from two NGOs to send to the annual meeting between civil society groups and regional leaders at the ASEAN summit in Phnom Penh in April. However, most Cambodian NGOs believe that the selection process was unfair and biased, and have stated that the government has prevented mainstream organizations and critical voices from being heard on an international stage. They claim that the organizations nominated by the government are obscure and unheard of in civil society circles and that the two organizations were selected because they are likely to be supportive of government views. As it turns out, the two selected NGOs were handpicked by the government seven months before the “open vote” to select the Cambodian NGO representatives took place in March.