A scapegoat would be innocent. I doubt even the Chinese would argue they haven't done anything. That's much of the problem generally and with this document specifically. If you latch onto things and investigate them to death you will in time run across actual wrongdoing. The danger is then that you cherry-pick these truths and spread them to each and every situation, giving the appearance of overwhelming wrongdoing. I think the people behind this document have done this knowingly.