Here, there is another dilemma. In the course of IVF, which is now widely used to treat infertility, along with a single or several embryos placed in the future mother's body, either natural or surrogate, the laboratory produces many other embryos. Before the insemination procedure, physicians choose which of them are more viable and healthy; some technologies allow future parents to choose the embryos with preferable sex and other qualities. After fertilization, �extra� embryos can be either destroyed or donated by parents for medical research and drug development and production. Many scholars believe that the usage of embryos for medical and research purposes, if not positive, is the lesser evil because instead is �dying,� they serve the good intention of helping other people.

Reproductive Technologies

Sketching a consistent guide to all the issues and concepts of bioethics is a difficult task since they often overlap, and the answers to some questions depend on how we have solved the other ones. Thus, the problem of reproductive technologies, which is one of the most disputable for the discipline, affects most other issues. On July 25, 1978, Louise Brown, the world's first �test-tube baby,� was born, which event revolutionized our understanding of human reproductive capabilities Ibid., p. 221. . This technology, initially designed for couples unable to give birth naturally, provided such an opportunity to many other social groups too. Among them, there are same-sex couples, single women, women, whose partner died, etc. It had even made it possible for a baby to have three parents instead of two See Rogers, K. �Three-Parent Baby,� Encyclopaedia Britannica. URL: [https://www.britannica.com/science/three-parent-baby]..

Let us briefly outline some main ethical issues of reproductive technology. It is noteworthy that many people oppose such research and manipulations in principle, stigmatizing it as �playing God� (especially Catholics and Orthodox Christians, but also many conservative Protestants, Muslims, and Jews.) The same people often refer to the �sacred mystery of giving birth to a new soul,� which will not tolerate any intrusions or the possible destruction of the family as a crucial social institute. However, besides religious concerns, the field features many problems, including:

- �Residual embryos� left after the IVF is done, which was the subject of the previous paragraph;

- The issue of embryos selection. Since scientists can read the DNA of all the fertilized embryos, they are also able to define which of them are the most viable, defectless, which have the most potent immunity to diseases, etc., so the parents can choose the �best one.� Sometimes their choice depends not only on more or less distinct health characteristics of the unborn children but also on esthetic or generally individual preferences. That leads, for example, to the practice of female fetuses abortion in China, which is widely known. Lesser known and more extreme cases take place in families of people with dwarfism or deafness when parents select the embryos with these particular features, although others are healthy and lack them. This may contradict the views and guiding principles of their physician.

- As an example of a hard reproductive dilemma, Guidry-Grimes and Veatch discuss the parents who decide to give birth a child to have a donor for another child that is sick. In a case, a girl born with such a form of leukemia that would allow her to live less that than five years without a bone marrow transplant. Since the family did not manage to find a suitable donor, they decided to have another child to take the bone marrow from it afterward. They were lucky and had a genetic match (which has about 25% success). When the child was three years old, it became a donor for its sister, which caused immense public criticism Veatch, Robert M., Guidry-Grimes, Laura K. (2019) The Basics of Bioethics. P. 228..

- Finally, the issue of posthumous reproduction overlaps such bioethical fields as death and informed consent. The question is whether the dead man agrees that his sperm would be mechanically taken from his body and used to give birth to a child after he deceased? Is it fair that a child would be intentionally deprived of the father? The list of countries that use posthumous reproduction features Anglophone states like the US, the UK, and Australia, but also Israel. As Shelly Simana explains, variations of legal norms in these countries include the absence of any regulations, the general prior consent of the dead person, and his consent concerning a particular partner Simana, S. (2018) �Creating Life after Death: Should Posthumous Reproduction be Legally Permissible Without the Deceased's Prior Consent?�, Journal of Law and Biosciences 5(2): 329-354. URL: [https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6121062/]..

Organ Transplantation

Although organ transplantation is a relatively old technology (for the first time in history, doctors successfully transplanted a human organ, which was a kidney, at Harvard Medical School in 1954) in terms of bioethics, it remains controversial. Groups of dissent remain, but the very legitimacy of transplantation has long been recognized even in such conservative actors as the Catholic and Orthodox churches, which I will address in the next chapter, dedicated to the religious dimension of bioethics. However, many technical procedures, like removal and replacement, are still under discussion. Today, medical science learned how to transplant many types of tissues and cells, nerves, skin, blood vessels, corneas, and heart valves. The list of transplantable organs features liver, kidneys, which are being transplanted the most often, �What You Need to Know About Organ Transplants,� WebMD. URL: [https://www.webmd.com/a-to-z-guides/organ-transplant-overview#1]. pancreas, heart, lung, and intestine; face and hand transplants are also in practice. Some vital organs, such as a kidney, a liver lobe, a lung lobe, and a pancreas segment, can be taken from a living person. Usually, such transplantation gives the recipient more chances to live longer Munson, R. (2009) �Organ Transplantation,� p, 214, In The Oxford Handbook of Bioethics..

The most frequent argument against organ transplantation from living donors is that somebody can impose on them the decision. In the case when one of the family members is ill, the rest can force the most vulnerable family member to donate an organ Ibid., p. 216. . Such a situation is likely to happen in China, where people value family the most and do not consider autonomy, human rights, and individual choice to have comparable value. Some Western theorists of bioethics even believe that it is necessary to forbid relatives to donate organs, as circumstances force them to become a donor. For example, moral and social pressure on parents in the case if their children are ill practically leaves them no choice Ibid., p. 218.. The more common position indicates that such a paternalistic method is unacceptable, so the assessment of surgery's risks and implications should be entirely left to the donor since the principle of autonomy is still of primary importance. Along with health issues, we have to take into account the needs and desires of the donor, so a person has to determine them on its own Ibid., p. 223.. The donor should have the right to change their mind at any time, even at the last moment before surgery. The absence of such principles can level the ground for buying and selling organs - not only at the �black market,� but also as a part of state-owned or private medical practice, which is inappropriate. That is why The United States National Organ Transplantation Act (1984) strictly prohibits trading organs, whether from living or deceased donors. Analogous laws exist in Great Britain, Europe, China, India, Russia, Mexico, and South Africa. However, the legislation in some Latin American, Scandinavian, and Asian countries implies that organs can be taken without expressed consent by an individual or the family after they are dead if no explicit objections are registered Veatch, Robert M., Guidry-Grimes, Laura K. (2019) The Basics of Bioethics. P. 255. .

Genetical Enhancement and Cloning

In 2003, a team of researchers from research institutes from many countries, including the US, Great Britain, Japan, France, Germany, and China, achieved a crucial scientific breakthrough, the Human Genome Project initiative. The main goal of this project, which was officially launched in 1990, was to completely decipher the human genome (its complete set of genes) and to create a �map� of more than three billion nucleotides. The research showed that the genome consists of about 30,000 genes and determined their order and location. However, the study did not discover the exact function of each of these genes, so it continues.

The genome of each human person is unique. As the official website of the National Human Genome Research Institute (US) states, �Having the essentially complete sequence of the human genome is similar to having all the pages of a manual needed to make the human body.� This will allow humanity to develop personalized medicine, diagnose ailments in a particular patient more accurately, and choose treatment methods with the most effectiveness in their case.

Eric T. Juengst reminds of the scientists' poetic and religious metaphor: they compared the results of the Human Genome Project with the Holy Grail Juengst, E. (2013) �Population Genetic Research and Screening: Conceptual and Ethical Issues,� p. 471. In The Oxford Handbook of Bioethics. . However, he notes that by itself, this project has no value for medicine. In essence, it presents a set of instruments that can be used for further research on the genome and for obtaining specific and practical medical solutions. There are two general ways to apply genetic technology, which are genetic treatment and genetic enhancement. The authors of The Basics of Bioethics distinguish between these two as follows: the first means that missing genes are added to a person, and the second indicates the manipulations with a healthy body. In medicine, the ethical difference between them is apparent. In the first case, the doctor must help the patient according to the generally accepted idea of duty, while in the second, there is no such necessity. This notion is not immune to speculation - like those of He Jiankui's experiment with the Chinese twins enhanced with the HIV-resistant gene (one of the parents had HIV.) Here, the problem is that he was dealing not with a disease, but with its probability. In the third chapter of our paper, we will consider this case in more detail.

Concerning genetic research, one cannot fail to mention such a breakthrough as the relatively new CRISPR / Cas technology, which He Jiankui used to modify the embryos' genome. It is the method of editing the genomes of higher organisms, basing on the immune system of bacteria. Although, in qualitative terms, it has no differences with previous ways of doing that, but makes it easier and cheaper. �It's about 1,000 times cheaper for an ordinary academic to do,� says George Church, a geneticist from Harvard Medical School �Scientists Debate the Ethics of an Unnerving Gene-Editing Technique,� The Washington Post. URL: [https://www.washingtonpost.com/news/speaking-of-science/wp/2015/12/01/historic-summit-on-gene-editing-and-designer-babies-convenes-in-washington/]..

Genetic Enhancement: Pro and Contra

Some researchers believe that we not only can, but we have to improve future generations through genetic technologies. For example, in his article titled Genetic Interventions and the Ethics of Enhancement of Human Beings (2007), Julian Savulescu emphasizes that a person must make his children not only healthy but also happy. To achieve that goal, the parents have to provide them with all the best conditions for a successful life. He argues that genetic intervention does not have qualitative differences from that on that the environment, upbringing, and even diet have on human life. Besides, he points to the fact that the features of early development also affect the structure of the brain, so genetic interventions are legitimate, too, as we cannot call them entirely artificial or unnatural Savulescu, J. (2007) �Genetic Interventions and the Ethics of Enhancement of Human Beings,� p. 521. In The Oxford Handbook of Bioethics, .

With the help of the brain's reward center, we can make ourselves more hardworking. That was already proven in the experiment with monkeys turned from �lazy� animals into �workaholics.� Specific genetic changes that can turn persons prone to polygamy into monogamous, save from drug addiction, etc.

There are five significant arguments in favor of human enhancement:

- Incoherency argument means physical/medical advantages do not differ from others. For example, taking steroids for an athlete who takes part in a race is not very much different from wearing specific types of sneakers;

- The line-drawing argument implies that any of our watersheds for what is permissible and what is not, are essentially arbitrary;

- According to the liberty argument, any person has a right to determine their values ??and means for achieving them on his or her own;

- �Resistance is futile� position claims that we will not be able to resist the opportunities of technological process, which, together with the market, will inevitably �seduce� people with longer life, beauty, more healthy posterity, and other benefits. People will pursue enhancements anyway, as they are available;

- Promethean argument means that people not only may, but they should enhance themselves, fulfilling the enterprise of being free creatures.

However, despite that the promises of genetic engineering in the field of disease treatment are impressive, these technologies raise many concerns. They touch upon their future and the grandiose impact that they may have on every person as a separate individual and the entire human race. The assessions of genetic enhancement in Western society are severely polarized. We will list only secular counterarguments, given that in most religions, such a severe interference in nature and human life is considered a sin or a violation of the natural order.

So, what could be a dangerous genome change:

- If human life is significantly extended, that threatens with its depreciation, and it may lose its meaning and traditional ways of scheduling it;

- If specific talents and inspirations can be programmed, they may too lose value and unique character;

- Parent-child relationships can be mechanized and made pragmatically;

- The argument of social stratification: since many people will not be able to afford enhancement, they will fall into the category of �second-class� people.

Most of the primary international agreements on genetic interventions drawn in the 20th century suggest that they are dangerous and unacceptable. One of them is the Council of Europe's binding international treaty titled the European Convention on Human Rights and Biomedicine (also known as the Oviedo Convention, 1997). There, Article 13 explicitly prohibits any interventions �seeking to introduce any modification in the genome of any descendants.� Convention for the Protection of Human Rights and Dignity of the Human Being with regard to the Application of Biology and Medicine: Convention on Human Rights and Biomedicine. URL: [https://rm.coe.int/168007cf98]. Another document, UNESCO's Universal Declaration on the Human Genome and Human Rights (the same 1997) asserts that �the human genome underlies the fundamental unity of all members of the human family, as well as the recognition of their inherent dignity and diversity.� Universal Declaration on the Human Genome and Human Rights. URL: [http://www.unesco.org/new/en/social-and-human-sciences/themes/bioethics/human-genome-and-human-rights/]. However, despite that these concerns and prohibitions are characteristic for most documents, there are some recent exceptions. In 2017, the report by a committee of the US National Academies of Sciences and Medicine titled Human Genome Editing recommends gene editing for human reproduction to be permitted under certain conditions, the list of which can be expanded Human Genome Editing. URL: [https://www.nap.edu/catalog/24623/human-genome-editing-science-ethics-and-governance].. Judging from this, we can probably expect more changes in this field shortly.

The operating ethical principles in human research support these concerns about genetic enhancement. As Guidry-Grimes and Veatch put it: �An examination of the standard guidelines for research involving human subjects will always reveal that the first, minimal condition for justifying studies on humans is that they are believed to offer hope of producing knowledge valuable to the society that cannot be obtained in any other manner.� Veatch, Robert M., Guidry-Grimes, Laura K. (2019) The Basics of Bioethics. P. 260. Besides, respect for persons in research also requires that they must have the right to quit at any time freely without fear of retaliation or any other consequences Ibid., p. 261. . The United States even identified special vulnerable categories of people who must be provided with additional guarantees concerning their rights in research. Such are, for example, prisoners who find it difficult to just get out of the experiment, or people in poor regions or ghettos where regular medical care is not available in sufficient quantities. Of course, this principle does not work in the case of gene research because embryos can hardly quit the experiment.

Therapeutic and Reproductive Cloning

Cloning of complex organisms (like mammals) has been invented and used for a long time. In 1996, the first successfully cloned mammal, the famous sheep named Dolly, was born. Scientists managed to achieve this success thanks to SCNT (Somatic Cell Nuclear Transfer) technology. It implies that the DNA of a fertilized egg is removed and replaced by that of another organism. The result is an organism with the same DNA, which is almost, although not wholly, identical to the maternal creature. After Dolly's success, animal cloning continued. Now it is used in agriculture and some other services like, for example, pet cloning Ibid., p. 230. . In January 2018, Chinese scientists under the supervision of Pu Muming (���疾), director of the Chinese Academy of Sciences' Institute of Neuroscience in Shanghai, cloned two macaques. Pu Muming noted that ideally, such experiments have to combine the SCNT and gene editing techniques�These Monkey Twins are the First Primate Clones Made by the Method that Developed Dolly�, Science. URL: [https://www.sciencemag.org/news/2018/01/these-monkey-twins-are-first-primate-clones-made-method-developed-dolly].. It is characteristic that macaques were called Zhong Zhong (�� ��) and Hua Hua (�� ��) - the names denoting the Chinese nation, which testifies of this scientific breakthrough's symbolism and profound socio-political significance.

As for humans, two types of cloning, therapeutic and reproductive, are considered. No official records of implementing the latter are recorded. However, the authors of The Basics of Bioethics suggest that it is �might not stay science fiction for long.� Veatch, Robert M., Guidry-Grimes, Laura K. (2019) The Basics of Bioethics. P. 230. In some countries, the law explicitly prohibits such attempts.

Therapeutic cloning is used to produce cells and tissues identical to the maternal body DNA, which are thus perfectly suitable for transplantation. It can solve acute issues with donor organs and other biomaterials necessary for patients but are in permanent scarcity. Besides, this technology eliminates the danger that organs will not take root, and patients will not have to take immunosuppressants, which affect the body in a generally negative way. Therapeutic cloning raises many bioethical questions. One of them is that it can provoke attempts to reproductive cloning. Another issue is the massive problem of stem cell use because living embryos are used and destroyed during the SCNT process. Concerning the public funding of this research, that is a severe obstacle Bonnicken, A. (2007) �Therapeutic Cloning: Politics and Policy�, p. 443. In The Oxford Handbook of Bioethics..

1.4 Alternative Approaches in Bioethics

Secular Alternatives

For contemporary postmodern culture, the concept of narrative is one of the crucial, so the stories are the principal object of research in many fields. The authors of The Basics of Bioethics emphasize the importance of narratives for human imagination and empathy Veatch, Robert M., Guidry-Grimes, Laura K. (2019) The Basics of Bioethics. P. 80.. What they call the �narrative ethics� involves a particular set of skills like attentiveness and receptivity. Within its framework, the doctor's reflection on the patient's story resembles his reflection on works of art Ibid.. Since narrative ethics includes many challenging issues, in bioethical research, it serves as a compliment, albeit very valuable, to the principlist approach.

In today's bioethics, feminism is a rather influential alternative approach. Its strong aspect is that it tries to take into account many factors and contexts from different areas. They include the physical and emotional state of a person, their social environment, connections, role in the community, economic situation, and other factors. It also pays particular attention to social oppression phenomena. Feminist ethics focuses on women, minorities, and other supposedly vulnerable groups of people. And although these principles, like other sets of principles, may contradict each other either in general or because different feminist approaches elaborate on different arguments, Guidry-Grimes and Veatch suggest that bioethics can make great use of feminism's critical apparatus.

Bioethics in Christianity and Islam

As we said above, every bioethics system develops according to many factors and always has a deep cultural background. Religions play a significant role in the formation of such a background. Thus, studying bioethics in China, we will inevitably address Confucianism, Taoism and Buddhism (without ignoring, of course, other system-forming factors), in Iran we will consider Shiite Islam, in Russia that is Orthodox Church, and in the US - some of the most common Christian denominations and others influential religions like Judaism. In this section, I will give a short overview of bioethics in several religions to show the diversity of bioethical concepts in the West and to have a better understanding of how they influence the mainstream in bioethics.

Of course, I recognize that there can be very different approaches to bioethics (as well as to anything else) within a particular religion or even within one of its branches. For example, there are significant differences in the Sunni and Shiite versions of Islam, or Lutheran Protestantism and Pentecostal Protestantism. Besides, the application of bioethics varies from country to country, due to particular location (urban or rural area, for example), depending on the level of population's education, personal qualities of religious leaders in a social group, etc. The broadest range of Protestant denominations includes both very liberal ones like those with female and homosexual clergy, and very conservative groups, like some Baptist, Evangelical, and Pentecostal churches in the US, which are often called �fundamentalist.� In modern Catholic bioethics, the double effect method has become widespread in solving dilemmas. For example, a pregnant woman, whose health and life is in danger, is allowed to have an abortion. However, sometimes in Catholic clinics, a woman can be misinformed about health risks because physicians avoid sharing information that can push her to abortion �ACLU, Michigan Woman Sue Catholic Bishops over Hospital Rules, � CNN, 02.12.2013 [https://edition.cnn.com/2013/12/02/health/aclu-catholic-bishops-lawsuit/index.html]..

Catholic Bioethics

Researchers of Catholic bioethics are lucky to have many sources and documents at their disposal. Catholics started discussing bioethics since its appearance as a discipline (from the 1960s). Moreover, they trace the history of Catholic bioethics to St. Augustine, who considered, among other things, suicide. The �library� of Catholic texts, which propose solutions to bioethical issues, is quite extensive: these are documents of the Second Vatican Council (they contain instructions to read �signs of the time,� that is, to monitor what is happening in the world and respond to innovations), Catholic Catechism of 1992, and many special encyclicals and directives:

- Humanae Vitae (1968) by Pope Paul VI, which refers to the problems of fertility, abortion, and contraception;

- Evangelium Vitae by John Paul II (1995), which contains statements on the death penalty, abortion, and euthanasia;

- The Declaration on Euthanasia (1980);

- Donum Vitae (1987) - an instruction that primarily addresses to in vitro fertilization questions;

- Dignitas Personae (2008) - the document which discusses the issues of reproduction technologies, genetic research, cloning, which he poetically calls �biological slavery,� and even animal-human hybridization.

There are many Catholic directives on the local and national levels, too: for example, it is US's National Catholic Bioethics Center The National Catholic Bioethics Center. URL: [https://www.ncbcenter.org].

Catholics have specialized institutes and institutions engaged in bioethics research - Pontifical Academy for Life in the Vatican, The National Catholic Bioethics Center, etc. Many articles are published on Catholic Bioethics annually. Besides, by �reading the signs of the times,� Catholics respond relatively quickly to the appearance of technological innovations that can raise new bioethical questions: in February this year (2020), the Pontifical Academy of Life issued a document titled Rome Calls for the Ethics of Artificial Intelligence, which refers to the need to study and develop ethical systems alongside IT technologies, which should be person-oriented. At the invitation of Pope Francis, this document was signed by Microsoft President and IBM Vice President, among others.

Catholic thinkers cover almost all relevant issues of bioethics. We will only briefly outline their main approaches - both those that agree with secular bioethics and those that present an original view of the problems.

The Catholic Church's proactive stance against abortion and stem cell use is widely known. As stated in Dignitas Personae, �The dignity of a person must be recognized in every human being from conception to natural death.� In the previous sections, I considered different points of view on when human embryos become the subjects of human rights. Catholics take a radical standpoint here, believing that this happens immediately after conception, at the moment when the unique genome of the embryo is formed. Therefore, from this moral point of view, neither abortion (if pregnancy does not threaten the health of the mother) nor IVF (which results in the discarding of many �extra� embryos) can be acceptable. There are other arguments contra IVF: Catholics state that it is ethically unacceptable to dissociate procreation from the integrally personal context of the conjugal act: human procreation is a personal act of a husband and wife, and any substitutions are substitution Instruction Dignitas Personae on Certain Bioethical Questions (2008) URL: [http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_20081208_dignitas-personae_en.html].. For the same reasons (though there are others, too: exploitation of a woman, traumatism for a child, etc.), the Catholic Church strictly prohibits the practice of surrogacy.

Recognizing that the question of determining death is the business of doctors, not ethicists and theologians, they agree with the criteria of brain death. The church supports organ transplantation if there is informed consent of the donor - then the procedure can be considered as a manifestation of the love of others. And concerning active euthanasia, Catholics take a negative position, considering it an interference in the divine order; in other words, suicide or murder.

The Catholic Church makes several strong arguments against the technologies of gene enhancement and cloning, both religious and non-religious. The first is that by changing the genome, and at the same time, the nature of man, the researcher puts himself in the place of the Creator. Catholics are concerned about the possible social consequences of introducing such technologies like eugenic mentality, stigmatization of people with disabilities, and a deep social stratification of people into those who can and cannot afford genetic improvements and those who do not. One popular contra argument can be considered both religious and non-religious: working with gametes, a scientist affects not only the entire body of an unborn baby but also its further offspring. Thus, transferring an already serious risk from one to a hypothetical multitude of people, the responsibility becomes extremely serious.

Orthodox Bioethics

The primary and most relevant document for studying the bioethics of the Russian Orthodox Church is the Fundamentals of the Social Concept of the Russian Orthodox Church (2008) Fundamentals of the Social Concept of the Russian Orthodox Church. URL: [http://www.patriarchia.ru/db/text/419128.html].. In many matters, Orthodoxy's ideas are no different from Catholic bioethics: it prohibits abortion (also without a severe threat to the mother's life), surrogate motherhood, euthanasia, and all types of IVF with the same main argument - this leads to the death of many embryos.

Orthodoxy declares the cure of the patient �the fulfillment of God's plan for man,� and therefore wholly allows organ transplantation and gene therapy.

In the case of incurable diseases, the Fundamentals call for patience, because suffering is the result of personal sins and �the general corruption and limitation of human nature.� The document indicates the importance of conscious preparation for the passing away of life, as well as the opportunity to show one's service to God for medical workers and relatives of a terminally ill patient in caring for him. The document also emphasizes the validity of passive euthanasia: delaying the death hour sometimes only prolongs the patient's torment, depriving a person of the right to a decent death.

Protestant Bioethics

I have already indicated that Protestantism is characterized by a wide variety of denominations, which sometimes represent opposing views on things. However, if we consider it in a somewhat �averaged� form, as it appears in the countries of its traditional distribution (Central and Northern Europe, Great Britain, the US, Australia, Canada), then we will see a fairly liberal position that is consistent with the concepts of secular scientific bioethics �Bioethics for Clinicians: 28. Protestant Bioethics,� Canadian Medical Association Journal, 05.02.2002. URL: [https://www.ncbi.nlm.nih.gov/pmc/articles/PMC99316/].. Of course, there are systemic exceptions: for example, the popularity of the idea of the manifestation of the divine will in a �miracle� in some Protestant denominations makes some of their representatives protest against disconnecting relatives from life-supporting devices, even with diagnosed brain death. A striking example of this behavior was the widely acclaimed Jahi McMath case Schmidt, S. (2018) �Jahi McMath, the Calif. Girl in Life-Support Controversy, is Now Dead,� The Washington Post. URL: [https://www.washingtonpost.com/news/morning-mix/wp/2018/06/29/jahi-mcmath-the-calif-girl-declared-brain-dead-4-years-ago-is-taken-off-life-support/]..

As well as representatives of other branches of Christianity, they oppose active euthanasia, abortion, and genetic research, but generally take a less �activist� position here. For us, it is important enough to note that it was the Protestants who played the main role in designing the concept of autonomy as a key notion of Western bioethics.

Islamic Bioethics

Islamic bioethics is generally the virtue ethics, and the decisions (fatwas) in this controversial field are taken by people with religious and social authority. In their table of chief virtues in various ideologies, Guidry-Grimes and Veatch attribute to Islam contentedness, gratitude, generosity, and magnanimity Veatch, Robert M., Guidry-Grimes, Laura K. (2019) The Basics of Bioethics. Table 1.. Or, in the document titled �Oath of a Muslim Physician,� the Islamic Medical Association of the US and Canada lists such virtues as honesty, modesty, mercy, fortitude, wisdom, and understanding Ibid., p. 85..

Unlike Orthodoxy and Catholicism, which have recognized high leaders, whose opinion is considered to be �official,� there is no such thing in Islam. While issuing fatwas, religious jurists use different arguments and contradict each other, which sometimes even takes the form of a �fatwa war.� Nevertheless, at least in theory, all the conclusions of the spiritual leaders must be consistent with the principle of maslaha, or the public good Rogozina, S. (2018) �The Body Does Not Belong to Allah Anymore?�, Archaeology of Russian Death, 6: 33..

In Islamic discussions, there are often many arguments both pro and contra, because the opinions in various bioethical issues are grounded in inherently pluralistic sources like Quran and Hadith, and interpret them differently. However, in the development of Islamic bioethics, one can single out some major trends that I would like to put into three categories. The first leitmotif is religious attitudes that bring Islamic conclusion closer to ones in other Abrahamic religions. They hold similar views in opposing active euthanasia �Jewish, Christian, Muslim leaders sign declaration against euthanasia�, Crux. URL: [https://cruxnow.com/vatican/2019/10/jewish-christian-muslim-leaders-sign-declaration-against-euthanasia/?fbclid=IwAR12iIxsygs07qDmqUJqjPX41dDn9C7BcaGlPtflT5b6Bt_4dLInvmiC2YQ]. and put forward the same arguments against contraception, which presumably contributes to debauchery, contradicts the family's very essence, and can be considered a child-killing However, Catholicism and Orthodoxy says so about contraception with an abortive effect.. The second trend is the unique attitudes of Islamic bioethics based holy scriptures. For example, in some circumstances, the Islamic tradition permits abortion until the embryo reaches 120 days because, at this age, God breathes a soul into it Ekmekci, Perihan E. (2017) �Abortion in Islamic Ethics, and How it is Perceived in Turkey: A Secular, Muslim Country�, Journal of Religion and Health, 56: 884-895. URL: [https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5215975/].. The disputes on organ transplantation take into account the confessional affiliation of people. Some fatwas allow organ transplantation from non-Muslims to Muslims, not vice versa; some forbid Muslims to donate to unbelievers, and the enemies of the faith. The third ones give Muslims, and especially the righteous ones, priority in the queue for receiving organ transplants Rogozina, S. (2018) �The Body Does Not Belong to Allah Anymore?�, p. 39.. Third, many Islamic theologians and jurists hold a positive attitude towards science and research, which helps it to develop Ibid., p. 49. . Such a view is due to the idea that the study and improvement of the world is one of the goals of human life and fall into the above-mentioned �playing human� category. It is noteworthy that family and society play a dominant role in Islamic ethics, which brings it closer to the approaches of Chinese and, generally, Eastern bioethics.

Chapter 2. Chinese Bioethics as a Discipline. Sources, Theories and Reconstruction Processes

In the previous chapter, I have explored the basic concepts and tools of Western bioethics - both in its mainstream (which is by no means full of diversity, debate, and seemingly insoluble dilemmas) and alternative �schools�, secular and religious ones. This chapter will be dedicated directly to Chinese bioethics and, in particular, to its theory. This part of the thesis has several goals:

- To discover the main features and trends in the subject of our study;

- To analyze several English-language collections of articles written by Chinese scientists and scholars actively engaged in its construction and a very interesting Chinese-language textbook on biomedical ethics, quite popular among medical and biology students, that will help us understand how Chinese Bioethics is forming and manifesting itself (both inside and outside Chinese culture - that is why we need sources in English, too);

- To compile a small dictionary of specifically Chinese terms that offer a special view of bioethical problems (with the exception of Confucian terms, the analysis of which in connection with bioethics is given in the many articles I studied, the selection and analysis of other words and expressions belongs to the author of the thesis);

- To �onduct a comparative analysis of problems and their solutions in Chinese and �general� bioethics.

In my opinion, Chinese bioethics has five major tendencies, or drivers.

1. Scientism in politics as a heritage of socialist culture inherited from soviet culture and mixed with a deeply rooted will to become a world-leader. As the Soviet Union was characterized by the desire to conquer nature and adopt science for the needs of society (as Russian revolutionary Sergey Minin wrote in 1922, science is a weapon of proletariat Lobazova, O. (2019) Sociology and Psychology of Religion: Religious Consciousness in Russia. Uright. P. 102. ), so it is characteristic for the Chinese as well. Even the latest constitution of Xi Jinping stipulates that the development of the state should be based on science and adapt scientific ideas Cheng, Y. (2018) �China Will Always Be Bad at Bioethics,� Foreign Policy. URL: [https://foreignpolicy.com/.2018/04/13/china-will-always-be-bad-at-bioethics/]..

In this respect, Deng Xiaoping carried out a very illustrative act: he decided to donate his cornea for transplantation purposes and other organs for medical research Faison, S. (1997) �Donation of Organs Is Unusual In China,� The New York Times. URL: [https://www.nytimes.com/1997/02/24/world/donation-of-organs-is-unusual-in-china.html]. . In leader's decision one can read not only that he indicated the lack of organs for transplantation in China, but also the paramount importance of science. Thus, he ignored the traditional Confucian concept of the body as that it should not be damaged under any circumstances.

This political orientation is rooted in the history of pre-socialist China. Qiu Renzong notes, that �Chinese intellectuals have believed that Mr. Sai (?����, science) and Mr. De (���搶, democracy) can save China from exploitation and humiliation by the powers. Thus, scientism is very popular: science and technology are thought to be capable of solving all issues facing China� Qiu, R. (2006) �Cloning Issues in China,� p. 55. In Roetz, H. (ed.) Cross-Cultural Issues in Bioethics.. In addition, it is quite obvious that it is important for China to be at the forefront in the global economy and seize primacy in such important areas as artificial intelligence and biomedical technologies.

Along with a number of other social and economic factors, this creates the basis for bold experimentation - for example, monkeys were first cloned in China �These Monkey Twins Are the First Primate Clones Made by the Methods that Developed Dolly,� Science. URL: [https://www.sciencemag.org/news/2018/01/these-monkey-twins-are-first-primate-clones-made-method-developed-dolly]. , human head transplantation studies are being conducted in this country �Human Head Transplantant Still Some Way Off, Chinese Surgeon Ren Xiaoping Says,� South China Morning Post. URL: [https://www.scmp.com/news/china/society/article/2120912/human-head-transplant-still-some-way-chinese-surgeon-ren-xiaoping]., and it was in China where the first human-animal hybrid embryo was designed Weiss, R. (2003) �Cloning Yields Human-Rabbit Hybrid Embryo,� The Washington Post. URL: https://www.washingtonpost.com/archive/politics/2003/08/14/cloning-yields-human-rabbit-hybrid-embryo/8a032b32-9983-46ad-90c8-acbf585e77ed/]. and the first genome-edited babies were born Cyranoski, D. (2020) �What CRISPR-baby Prison Sentences Mean for Research,� Nature. URL: [https://www.nature.com/articles/d41586-020-00001-y].. I will analyze these cases in the third chapter of this work, which is dedicated to the legal and public opinion issues regarding bioethical problems in Chinese society.

2. Chinese scholars have long wanted to create Chinese bioethics, which would reflect all the cultural, social, and political features of the country. A group of researchers led by Qiu Renzong (a �leader� of Chinese Bioethics both in China and abroad, he introduced many general bioethical concepts in his country and introduced local bioethics to the English-speaking word); start from the point that global and universal bioethics is impossible, as different societies have different values. So, the Chinese have to reconsider their Confucian, Taoist, and Buddhist heritage and elaborate their own system of bioethics. Julia Tao Lai Po-Wah, professor at City University of Hong Kong, explicitly calls her Asian version of the Western notion of autonomy �a rival model.� Po-Wah, J. (2004) �Confucian and Western Notions of Human Need and Agency: Health Care and Biomedical Ethics in the XXI Century,� p. 20. In Qiu, R. (ed.) Bioethics: Asian Perspectives. I will address this issue in more detail later. Now, I would like to take a closer look at some examples of how the construction system operates.

As we have seen in the first chapter, bioethics is a complex discipline with an extended set of tools and a critical apparatus. But taken schematically, the �bioethical mechanism� has two main tools: principlism and consequentialism. The first assumes that we rely primarily on moral imperatives and values: in Western ethics, they mostly often are patient's well-being and autonomy, justice, and honesty. The second address the consequences of our actions, whatever they are, and to what we are supposed to do to achieve a particular result. If we consider Chinese bioethics in this binary system, it is clearly inclined to consequentialism. In his article on the Chinese �one family, one child� politics, Tang Refeng says that, generally, it is terrible to restrict people in their reproductive rights. Still, since it has shown positive results, it should also be recognized as positive Tang, R. (2004) �Chinese Population Policy: Good Choice and Right Choice,� p. 173. In Qiu, R. (ed.) Bioethics: Asian Perspectives. .

The most important feature of Chinese bioethics (and the way it is being constructed) proceeds from the basic characteristic feature of the Chinese and, broadly speaking, the Asian mentality: a primary emphasis on sociality and family. Most often, Chinese bioethicists question such fundamental Western values ??as individualism, autonomy, and human rights. In their opinion, as far as a person does not exist autonomously and is always incorporated in a process of social interaction, only the effect of our actions on the society really matters. As analyzed by Chinese scholars, this principle is fundamental and originates from such a crucial Confucian value as xiao, or filial piety.

Qiu Renzong complains that Western specialists in bioethics often misunderstand and show the lack of sensitivity to the unique Chinese culture. Calling for more in-depth dialogue, he quotes from Confucius: �Harmony is not becoming identical� (Analects, 1.12 and 13.23). Thus, he invites Western scholars to seek common grounds and preserve differences at the same time. The first steps he proposed in his 2006's article was the cooperative prohibition of human reproductive cloning (an actual problem for Western ethicists as well), and negotiations on some other pressing issues like human embryonic stem cell research and therapeutic cloning Qiu, R. (2006) �Cloning Issues in China,� p. 50. In Roetz, H. (ed.) Cross-Cultural Issues in Bioethics..

I suppose that thanks to the efforts of Chinese scholars Confucianism is and will be taking significant part in the formation of Chinese bioethics. Gerhold K. Becker, German philosopher and founder of Hong Kong's first Center for Applied Ethics, thinks that the role of Confucianism in Chinese bioethics is exaggerated. He refers to the fact that over the centuries in its history and until nowadays Confucianism had many spiritual rivals and also has different schools and opinions within itself Becker, K.G. (2006) �Chinese Ethics and Human Cloning: A View from Hong Kong,� p. 115. In Roetz, H. (ed.) Cross-Cultural Issues in Bioethics.. The thesis' author does not agree. Even if the initial picture proves Becker correct, the massive revival of Confucianism in China in recent decades makes it very likely to succeed in bioethics, too. Indeed, Confucianism can have different answers to bioethical questions, but due to the common goal and common will of �reconstructors� they can be unified and establish an advisory system able to influence political decisions.

3. Specific body perception (the importance of its integrity and harmony), which is characteristic for Chinese thinking and Chinese medicine. In our opinion, along with philosophy of natural life and natural order expressed in the Taoist tradition, it can have a serious impact on the development and practices of local bioethics. Here, the typically Chinese attitude to the historical and cultural background is especially important. On the one hand, there are people who naturally and unconsciously adhere to what we might be calling �superstitions.� Here is a typical case I have founded in the Chinese textbook on biomedical ethics: a male patient underwent kidney transplantation in a Shanghai clinic. A year later, he returned and asked the transplant to be taken back because it was unlucky (bujili, �s �g��, and now he is afraid that his family and descendants may suffer because of it. Shi Weixing, the author of the textbook, suggests that this superstition came from the Confucian notion that one should not harm a body that he or she inherited from the parents - which means not harvesting organs among other things, - and that an organ of a dead person can be harmful because of that Shi Weixing (2010) Biomedical Ethics (Shengwu yixue lunli xue). P. 184.. It is also believed that the Chinese refuse surgical interventions, especially in the abdominal cavity and chest, because of the idea of ??qi. They think that in this case, they can lose their vital energy.

On the other hand, the Chinese show more respect and tolerance towards archaic traditions and beliefs than an average resident of Western countries. For example, in China, the practices of traditional healing are embedded in modern medicine and affect the daily life of many people, who do not consider them as a relic of the long-forgotten past. Besides, traditional medicine exists on the periphery, but still within the field of scientific knowledge. There are many state-owned traditional medicine clinics in the country. According to the sociologist Jing-Bao Nie, the idea of Chinese medicine as a nonsense and superstition, which need to be overcomed, was widespread in the first decades of the 20th century. Now, the situation has changed. Sociologist uses rather value judgments calling those, who supports traditional medicine, the �progressivists�; according to him, they represent and a regular point of view in Chinese society. He writes that �progressivist critics assert that there exists merely a small portion of unscientific content in Chinese medicine, and that, on the whole, traditional medicine is a science with its own theoretical foundations and practical values. To traditional medicine, they believe, what is necessary is to discard the dross and select the essence.� Nie, J.-B. (2011) �Human Drugs in Chinese Medicine,� p. 171. In Fan, R. (ed.) Confucian Bioethics. He calls the opposite position �iconoclastic�, which can be evaluated as a biased and emotionally charged definition.

4. The market factor. If we compare the Chinese situation with that of Europe and the United States in terms of legal regulation of biotechnologies, we would not find such rigorous regulatory framework and active ethical committees. Besides, intense competition and a powerful market force characterize Chinese society. These two factors create a fertile ground for multiplication of biomedical procedures and experiments. Qiu Renzong points out that such �research centers as Beijing Human Genome Research Center, Shanghai Human Genome Research Center, and Genome Research Center of Chinese Academy of Science, are all integrated with a company which may produce something for profit on the basis of genetic research.� He also quotes from an interview with a prominent scientist published in Beijing Youth [Beijing qingnian bao, �k���”N?], where he says, among other things, that �genes are money� and �science and technology is the first productive force.� Qiu, R. (2006) �Cloning Issues in China,� p. 70. In Roetz, H. (ed.) Cross-Cultural Issues in Bioethics.

5. In contrast to many of what I have said above, China does care about its internal and external reputation. That is why, I suppose, the adverse reaction of the scientific community to the experiment with genetically modified children was so intense. The scholars emphasize that in its bioethics development, China respects international standards and adhere to universal moral values.