Presbyterian Church Of Australia Aust Presbyterian World Mission Committee: charity review

This is a charity review of Presbyterian Church Of Australia Aust Presbyterian World Mission Committee – yes, I’ve got the name right – (PWMC), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.

For the previous review, see here.

Are they responsive to feedback?

  • I sent them a draft of this review. Like last year, they chose not to comment.

Is PWMC registered?

What do they do?

  • ‘What do we do?
    • aid and refugee work
    • audio distribution of the Bible
    • Bible translation
    • church planting
    • teaching English as a Second Language
    • Evangelism
    • IT support
    • mission aviation
    • primary/secondary education
    • short term work parties to Vanuatu
    • theological education
    • training Australian indigenous leaders
    • university lecturing
    • …and many other activities that help spread the gospel [APWM Information Leaflet, here.]
  • PWMC is a national organisation, a committee of the General Assembly of the church in Australia [The Presbyterian Church of Australia, Constitution, Procedure and Practice, paragraph 5.(a), governing document, ACNC Register]. It appears from the NSW Property Trust Act 1936, that the NSW church looks after all the affairs of the General Assembly [Chapter 12 of the above document].

Do they share the Gospel?[2]

  • Although it is only one thing in this long list, one would expect that at least some of the missionaries doing good works are also sharing the Gospel.

What impact are they having?

  • There is no indication that they are assessing their impact. (I searched for ‘outcomes’ and ‘results’ too.)

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • The figures for PWMC are contained within the financial statements of the Group, those of the Presbyterian Church (New South Wales) Property Trust, along with those for eight other Presbyterian organisations. So no calculation is possible.

Do they pay their board members?

  • A 481-page document and unfamiliarity with the relationship between the parts of that document meant that I didn’t check whether they can pay such fees.
  • There is insufficient disclosure of expenses to say whether anybody in the Group paid their board members, let alone PWMC (one of nine organisations in the Group).

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

What choices do you have in how your donation is used?

Is their reporting up-to-date?

  • They don’t have to report, their figures being included in a Group Financial Report.
    • That Report was submitted four months after the year-end, seven weeks earlier than last year.
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 13 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: One wasn’t required.
    • It wasn’t required because of PWMC’s membership of the Group (see above). But even without this, it wouldn’t have to submit financial statements because it is a ‘basic religious charity’. The legislators apparently thought – I’ve not been able to find the reasoning – that there was enough accountability and transparency for you in the requirements of the religious system to which these charities belonged.
  • Financial Report 2016: One wasn’t required.
  • Group AIS 2016: Yes – although I don’t think the control of nine diverse Presbyterian organisations, one of which is the national ‘Missions Committee’, is fairly described as ‘Providing administration support to Presbyterian organisations in NSW’.
  • Group Financial Report 2016: (the report that includes PWMC’s figures): No, no true and fair view.
    • To produce the type of financial statements that imply that any stakeholders, past or prospective, can request a body controlling nine charities, earning $33.92 m p.a., and with 300 staff, can expect a positive response to their request for financial statements tailored to their needs is ridiculous.

What financial situation was shown in that Report?

  • No information on PWMC is available. You must trust the holding company. If this is not enough for you, then contact PWMC.

Where were your (net) donations sent?

  • Nothing is disclosed.

What did the auditor say about the last (Group) financial statements?

  • The auditor, Meredith Scott for Ernst & Young, gave a ‘clean’ opinion.
  • But
    • as it’s on the consolidated financial statements, statements where PWMC is mentioned only on the cover as one of nine other entities whose figures have been included,
    • and as it’s accepting of special purpose financial statements (above),
    • you might question how much comfort on PWMC you can take from that.

If a charity, is their information on the ACNC Register complete/correct?

  • No
    • An absence of countries under ‘Operates in (Countries)’ does not match the website information.
    • Is it really the case that just two people govern this charity?
    • ‘Who the Charity Benefits’ is blank.
    • Admittedly it’s only a trading name, but it’s incorrect (under ‘Other Name(s)’

Who are the people controlling the organisation?

  • There’s nothing about directors or a governing body on the website.
  • ‘Responsible Persons’ on the ACNC Register shows two people:
    • Peter Merrick
    • Stephen Smith
    • The governing document says that there are considerably more than two people on the Committee:

To whom is PWMC accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used in the website footer in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means PWMC’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • They are accountable because of their membership of Missions Interlink.
    • However, when they describe their membership, they make no mention of the accountability aspect.
      • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. I only checked in the name that they use on the website, the name that they told me last year was ‘the correct name’ (private email), Australian Presbyterian World Mission; ‘Fundraising’ is not mentioned on the website, so maybe their operations don’t include fundraising. But the internet invitation is fundraising. If their compliance with these laws is of concern to you, I’d ask them to explain.
  2. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

PeaceWise Ltd: charity review

Charity review of PeaceWise Ltd (PeaceWise[1]), an organisation that seeks donations online, and is accredited with the CMA Standards Council (a ‘Foundation Partner’). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

  • There is a PeaceWise ‘Complaints Policy’ on the website.
  • I sent them a draft of this review on 2 January. They responded the next day, requesting a month’s extension. Two days before the due date, they asked for another few days. When they responded on 9 February with comments, I agreed to a few changes and gave my reasoning for not making others. Unfortunately, despite a 14 February follow up request for what they wanted published, they have not responded. Apart from the correction of errors, I have therefore only included their comments where I told them that I would.

Is PeaceWise registered?

  • As a charity, yes.
  • PeaceWise is a public company, a company limited by guarantee.
    • It is not permitted to omit ‘Limited/Ltd’ at the end of its name. As it does on its website and in social media.
  • It has one business name, Peace Wise.
    • The Register shows PeaceWiseKids as a name they are known by. It is not registered.
      • PeaceWiseKids has its own website, but no ABN.
  • PeaceWise has four trademarks, ‘Peacewise’, ‘Peacewisekids’, and the two logos you see on its website.
  • The ACNC Register says that PeaceWise operates all over Australia. And it seeks donations on the internet.
    • It has fundraising licences in New South Wales, Queensland and Tasmania. There are three other states that have a licensing regime applicable to charities. PeaceWise does not explain why it thinks that it doesn’t need a licence in those states.
      • Ministry comment: PeaceWise has not registered in other states because of the statutory definitions of the entity or activities covered by the state or because of various exemptions such as the thresholds for minimum donations within the particular state.’
    • Whether or not it uses street collectors is not disclosed.
      • Ministry comment: PeaceWise does not use street collectors.’
  • PeaceWise operates overseas, per the ACNC Register, only in New Zealand.

What do they do?

  • See here.
  • The ‘Annual Report from PeaceWise Chair Jeroen Bruins’, combined with the Directors’ Report (Financial Report 2016, below), gives a good insight into what PeaceWise does.

Does PeaceWise share the Gospel?[3]

  • Some of their work allows them to do this.
    • Ministry comment: ‘We ask you to correct this. We consider that the correct answer should be “Yes: its website and newsletters are full of the Gospel. Its training is based on the Gospel. Its statement of beliefs in its constitution is unashamed mainstream Christian. Whilst its activities may not be equivalent to a Gospel sermon, this organisation is, in Gospel terms, way beyond a mere good living and social concern charity. I am informed by PeaceWise that: “Our peacemaking teaching and training is based on biblical principles and very clearly focused on and following the teachings of Jesus, the Gospels and NT. We help people in conflict to reconcile with God and those they are in conflict with. This often requires repentance, confession and seeking forgiveness to the ones they are in conflict with. This can only be done on the basis of the Gospel and the saving sacrifice of Jesus. Reconciliation is the heart of the Gospel and comes clearly through in our ministry.’

What impact are they having?

  • In the Directors’ Report, the directors say that
    • Performance in non-material (sic) terms relates to how many lives are impacted by the hope-giving work of the ministry, how many relationships are restored, how many people draw closer to Jesus, how many people learn to deal better with conflict in their marriages, workplaces, families and other contexts. This non-material aspect of ministry is more difficult to measure but vitally important.
  • If these things were measured, the results are not reported.
    • Ministry comment: (What they wanted me to add to the above) ‘However, the Chairman’s Report describes in extensive detail many examples of the impact the ministry is having in these areas.’
  • Regular program evaluations are required by the accreditation held with the CMA Standards Council (Standard 5.6). Evaluation is not mentioned on the website.
    • If evaluations are new to PeaceWise, we might not see one for three years (the CMA standard).

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • The expenses are not classified in a way that allows the calculation of this figure.

Do they pay their board members?

  • This is permitted by the constitution.
  • It is not possible to tell from what PeaceWise have published whether they have taken advantage of this ability.
  • If they are paying these members, they are contravening the CMA Standards Council requirements (Standard 3.7).
    • Ministry comment: (What they wanted me to say instead of the above) ‘Their last annual report discloses that their CEO is remunerated $36,000 per annum. I am informed that Board members are all volunteers and are not paid. The National Director (CEO), through a company, consults part time for the ministry and receives financial compensation for his managerial role as CEO. He is a board member, but not paid for this role. The services of the CEO are provided by a contract from Burgess Consultants Pty Ltd, a consulting firm which provides services to a large corporate for the remainder of the CEO’s time each week.’

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Comodo is used, so yes.

Is their reporting up-to-date?

  • Yes (lodged three months after their year-end, a month earlier than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • Why is ‘National Director Fees’ ($36K) omitted from ‘Employee expenses’?
    • The ‘Description of charity’s activities and outcomes’ does not describe 2016’s activities[4].
    • Outcomes are not mentioned.
  • Financial Report 2016[5]: No.
    • Income Statement:
      • The directors declare that one of their aims is to produce a surplus, yet there is no reason given for the second substantial deficit in a row, nor what they are doing about it.
      • There is no information about the sizeable grant that was received (31% of revenue).
      • 43% of the expenses are included in the single item ‘Other expenses’.
      • ‘National director fees’ are, without explanation, not included in ‘Employee benefits expense’.
      • There is no explanation of the item ‘Consumables used’, 23% of expenses.
    • Statement of Financial Position:
      • There is no information about their role as a trustee (‘Cash and cash equivalents’).
      • 7% of the assets are in ‘Patents and trademarks’. But there is no policy Note on intangibles, so there is no defence that the figure recorded for the four patents it holds is not an overstatement.
      • ‘Inventories’ are 12% of the assets, yet there is no description and no policy Note.
      • 76% of the liabilities ($63K), three funds and a project, are questionable as liabilities. There is no Note explaining the items.
      • The information for current liabilities in the Statement of Financial Position does not match the Notes.
    • Notes to the Financial Statements:
      • The item ‘Unearned Income ($44K) in the ‘Reconciliation of cash flow… (Note 11), does not match anything in the Statement of Financial Position.
      • Many of the Notes normally included in Note 1 are missing.
      • The is no information on related parties.
    • There is no reference to the ACNC Act in either the Directors’ Declaration, or the Independent Auditor’s Report.
    • Two required lines in the Statement of Changes in Equity are missing.
    • PeaceWise values feedback, and its display of the CMA Standards Council seal implies thatthe organisation takes governance, accountability and stewardship seriously’, so, in addition to the suggestions flowing from the above points, plus other sections of this review, you might also ask about this decision:
      • The directors have chosen (without giving their reasons), to produce the lower disclosure special purpose financial statements. This is instead of the type of statements that is appropriate if stakeholders need regulatory intervention to ensure that they get the information they need to make decisions. With a range of people and organisations contributing revenue, a request for funds from the public, and operations all over Australia (including ‘regional ministry coordinators’ in four states), it is difficult to see how PeaceWise would be comfortable with supplying a tailored financial report to any stakeholder that asked for one.
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore PeaceWise is not complying with Standard 6.1 of the CMA Standards Council standards (see above).
      • Ministry comment: (What they wanted me to write). ‘PeaceWise has advised me that they have asked their auditor to consider these points.’

What financial situation was shown by that Report?

  • Despite an aiming ‘to finish each year with a surplus rather than a deficit’ (Directors’ Report), last year’s deficit was repeated.
    • It is, however, slightly less as a percentage of revenue (negative 13% to negative 11%).
  • Employee benefits was 28% of expenses (down from 34%).
    • But as a measure of payments for labour, it does not include what was paid to the National Director.
  • Current assets as a multiple of current liabilities (working capital) declined markedly from 3.6 times to 2.0 times.
  • With zero non-current liabilities, $14K of long-term assets is sufficient.

What did the auditor say about the last financial statements?

  • The auditor, John Stephens F.C.A., for Omniwealth Accounting & Audit, issued a ‘clean’ opinion.
  • However, before you decide how much comfort to take from this opinion, I suggest you read again the ‘Financial Report 2016’ section (above).

If a charity, is their information on the ACNC Register complete/correct?

  • Yes

What choices do you have in how your donation is used?

  • ‘where it’s needed most’
  • ‘kids project – peacewisekids’
  • ‘help build new adult courses’

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) is missing John Hollier and Deborah Bensted:
  • The board is responsible to the membership. The number of members is not disclosed.
    • Ministry comment: ‘The Board is the membership – there are no other members.’

To whom are PeaceWise accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means Peacewise’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • PeaceWise has gone beyond the charity tick and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – see the right-hand side of each page. For this is must abide by the Council’s  Principles and Standards of Responsible Stewardship.
  • PeaceWise is also accountable for some things, as a company, to ASIC.
  • Ministry comment: ‘As a Christian Charity (sic) we believe we are also accountable to God.’

 

 

  1. The name on the ACNC Register is incorrect. It is ‘PeaceWise Ltd’, not ‘PeaceWise Ltd’.
  2. I agree with Randy Alcorn [Money, Possessions, & Eternity, Tyndale, 2003] when he says that ‘Any Christian leaders who resist financial accountability make themselves suspect.’ [page 425].
  3. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  4. Given that this is in an ‘Annual Information Statement’, it is not unreasonable to think that the ACNC expects a description of what the charity did in the year that is the subject of the Statement, not just a description of what it does generally every year.
  5. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.

IJM Australia Ltd: charity review

A charity review of IJM Australia Ltd (IJMA), an organisation that seeks donations online. A review in response to a question to me by a potential supporter of IJMA. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(For the previous review, see here.)

Are they responsive to feedback?

  • In the ‘2016 Annual Review’ they say that ‘We value your feedback and strive to address any complaints promptly. You can contact us in the following ways:…’ (page 26).
  • I sent them a draft of this review. Like last year, they responded with comments. Their general comment is immediately below, the others in the section to which they relate.
    • We are more than happy to discuss the details of our work, operations, financial and impact reports.
      We’re currently preparing for our 2017 audit and appreciate your review and the opportunity to respond and provide further detail. Your insights are helpful not only as we prepare for audit but also as we work to continuously improve our operations and the information available to existing and potential supporters.

If you or your client want to hear more about our work, we also have our Australian Prayer Gathering coming up in Sydney on March 3, where we will be profiling and praying for IJM’s work globally. 

Please let me know if there is any more information we can provide.

Is IJMA registered?

  • As a charity, yes.
  • Not to be confused with www.ijmaustralia.com.au, International Junior Miss.
  • IJMA is a public company, a company limited by guarantee.
    • It has the provisions in its constitution to allow it to omit ‘Ltd’/‘Limited’ from the end of its name.
  • Contrary to what is implied on the ACNC Register, IJMA has not registered the other name that it uses, International Justice Mission Australia.
    • Ministry comment: We are currently looking at our registered names with the ABN register and ASIC and will correct any inconsistencies.’
  • IJMA operates – according to the ACNC Register – throughout Australia and in India, Kenya, Philippines, and Uganda.
  • It is registered to fundraise in all states that have a licensing regime.

What do they do?

  • Generally: The section ‘Objectives’ in the constitution begins
    • IJM Australia is established to work from a basis of Christian belief and values for the charitable purpose of providing relief to people suffering from poverty, distress and helplessness within countries declared by the Minister for Foreign Affairs to be developing countries under section 30-85 of the Tax Act….
  • More specifically: IJMA is a partner office of IJM (‘IJM Global’). IJM is
    • working to end modern-day slavery, human trafficking and other forms of violence against the poor by rescuing and restoring victims, restraining perpetrators, and transforming broken public justice systems.
  • And in 2016: not what the website says – that’s about IJM globally – but what is written in the ‘2016 Annual Review’:
    • In 2016, IJM Australia partnered with three offices in the field supporting programs to rescue victims of slavery and violence, bring criminals to justice, restore survivors, and strengthen justice systems. Total funding provided by IJM Australia to overseas programs was $458,498.

In Cebu, the Philippines, IJM shifted its focus from more traditional forms of commercial sexual exploitation of children to online sexual exploitation of children (cybersex trafficking) – a growing and devastating form of modern day slavery.

With the support of IJM Australia, IJM Cebu rescued 42 victims from sex trafficking, and secured the convictions of 23 perpetrators. IJM Cebu lawyers and The Inter Agency Council Against Trafficking prosecutor also successfully advocated for the use of plea bargaining in cybersex trafficking cases through 2016, securing convictions without victims (children) needing to testify against their perpetrators.

In Kenya, IJM Australia provided support to IJM’s Police Abuse of Power system reform program which works to seek justice for those who have suffered at the hands of authorities who should protect them. Many of the planned activities were placed on hold in June 2016 following the murders of IJM Kenya investigator Willie Kimani, IJM client Josephat Mwenda and driver Joseph Muiruri, as the team focused on responding to the tragedy and the trial of the perpetrators that began shortly afterwards.

Following the success of the trial advocacy training in Uganda in 2015, IJM Australia worked again with IJM Kampala to design and implement a trial advocacy training program for 30 Ugandan Resident State Attorneys. To facilitate the training, IJM Australia recruited three senior members of the Victorian Supreme Court, NSW Bar and Victorian Bar to run four consecutive days of teaching sessions. The training was aimed at enhancing the technical capacity of the Ugandan Attorneys (including trial preparation, advocacy and case management) and supporting appropriate sentencing in property grabbing cases. The training was a great success and will be run again in August 2017.

In Australia, we continued engaging with our faithful supporters in a number of different activities:

IJM AUSTRALIAN PRAYER GATHERING…

TIME FOR JUSTICE CAMPAIGN…

SPEAKING ENGAGEMENTS & MEDIA

  • In the Annual Information Statement (AIS) 2017 they said that they planned to make the following changes in 2017:
    • In 2017 IJM Australia expects to provide increased support to combat bonded labour slavery in India. In 2017 we have also expanded our national training programs to mobilise more Australians to seek justice for the poor, and have increased our advocacy efforts and working with government and other agencies to address the demand side of cybersex trafficking here in Australia.
    • Ministry comment: ‘While our 2017 ACNC reporting isn’t due yet, we can joyfully confirm that IJM Australia did achieve these goals – we substantially increased our financial support to combatting bonded labour slavery in India in 2017, and also contributed government initiatives to address trafficking and Australian legislation concerning the online sexual exploitation of children/cybersex trafficking of children.  This work will be profiled in our 2017 Annual Report which will be released soon and also included in our next ACNC AIS.’
  • The register of Victorian licensed fundraising licences says that GoFundraise Pty Ltd and Everyday Hero Pty Ltd are the ‘Commercial fundraisers working with the principal fundraiser’. But there are more: Benojo and mycause.
    • Ministry comment: We have referred back to our last annual return paperwork submitted and we did disclose both Benojo and MyCause as platforms we use in two separate areas of the return form to CAV. It appears that these changes weren’t updated on the CAV site.   We have contacted CAV to confirm this and the changes should be reflected soon.’
    • They do not disclose whether they use street collectors
      • Ministry comment:
  • The format of the Statement of Income and Expenditure and Other Comprehensive Income, plus IJM’s ‘Objectives’ (see above), suggest that it is seeking Australian Council for International Development (acfid.asn.au) membership (and government overseas aid grants).

Does they share the Gospel?[1]

  • No.
  • IJMA does not have ‘Advancing Religion’ as an ‘Entity Subtype’ on the ACNC Register.

What impact are they having?

  • There is no information on the impact of IJMA, that is, the Australian organization.
    • Ministry response: IJM Australia is part of the global organisation and as such where IJM Australia contributes directly to financially support the work of IJM teams, for example in the Philippines or Kenya, then we have contributed to the outcomes of that work. The programs and activities detailed in the ACNC AIS under the activities and outcomes also speak to the programs specifically led or delivered by IJM Australia, such as the training of 30 Ugandan attorneys to more effectively address crimes of property grabbing from vulnerable widows, thereby contributing to the strengthening of the local justice system to better protect the poor from violence.  See also notes above regarding the Quarterly Impact reports we are currently developing for donors.’
  • The website has a presentation of some statistics showing that ‘justice system transformation’ is effective. This involves the efforts of more than the IJM organization though.
  • An external evaluation of the program in the Philippines validated IJM’s theory of change.
    • To see the thinking behind what IJM does (and therefore what you fund), read The Locust Effect, by IJM founder and President Gary Haugen.
  • For IJM’s impact, see GuideStar’s Charting Impact Report.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If we define impact delivery as ‘Funds to international programs’, then 62% of the expenses are ‘administration’[2].

Do they pay their board members?

  • Such payments are prohibited by the constitution.
  • There is insufficient disclosure of the expenses to check for a payment.
    • Ministry comment: ‘IJM Board Members are volunteers and do not receive sitting fees for their services on the Board.’

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • If you chose to give via credit card security is not mentioned.
    • Ministry comment:Our website and online giving forms are secured with SSL technology compliant with PCI requirements and the Secure Padlock is displayed in the url bar.  Our website also provides the ability to give via PayPal which also maintains PCI compliance.

Is their reporting up-to-date?

  • Yes (but on the last day allowed, six months after their year-end; one day earlier than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 13 months ago.
    • Ministry comment: Our reporting year is January 1 – December 31 (not July 1 – June 30), and as such the audited financials will be uploaded to our website, ACNC and also provided to relevant state departments overseeing fundraising with our annual returns once they are complete.’

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No.
    • Two names under ‘Other names…’ are not registered names.
    • ‘Other Income….’ does not match the figure in the financial statements.
    • The financial statements say that all the grants were ‘made for use outside Australia’, not some in Australia, and some outside.
    • Ministry comment: Programs supported inside and outside Australia have been captured in both the audited financials and in the AIS financial report, however we will talk to the auditors to look at how we can increase the consistency across the two.’
    • No outcomes are given.
    • Ministry comment: ‘See notes under impacts above. We are also in the process of developing more detailed quarterly Impact Reports for donors which are likely to be implemented in 2018.’
  • Financial Report 2017: No
    • For an organization that operates all over Australia and four countries overseas, has a professional staff of 12 and 70 volunteers, seeks donations on multiple public platforms, and receives $921K in donations, special purpose financial statements do not give the required true and fair view.
      • Ministry comment: We are looking to move to General Purpose statements as we grow.’
    • In addition
      • there is no Note on related parties (an ACNC expectation).
        • Ministry comment: We will raise this question with the auditors for the 2017 audit. Related party information was submitted to the ACNC in AIS reporting.’
      • the significant revenue item, ‘Seed Funding’, is not explained.
        • Ministry comment: Seed Funding was provided to IJM Australia by IJM’s global headquarters to support the establishment of the Australian operations.’
        • The ‘2016 Annual Review’ identifies it as a donation to IJMA from IJM. Why then is it not classified as a donation?
      • there is a mixed classification of expenses
      • some of the Notes that should be included, even in special purpose statements, are missing.
        • Ministry comment: ‘We will raise this question with our auditors for review.’

What financial situation was shown by that Report?

  • Last year’s result of 12% of revenue dropped to only 1% this year.
  • Employee expenses are 31% of expenses.
    • Based on the full-time equivalent figure in the ‘2016 Annual Review’, the average remuneration is $69K.
  • Funding from IJMA (‘Seed Funding’) decreased from 375K to 245K, and will be zero in 2018 [2016 Annual Review].
  • No obvious concerns with the financial structure.

What did the auditor say about the financial statements?

  • The auditor, Jeffrey Tulk, for Saward Dawson, gave a ‘clean’ opinion.
  • Before you conclude on how much comfort you should take from this opinion, please
    • read about the meaning of ‘clean’ here and here, and
    • re-read the section ‘Financial Report 2017’. (To do the audit, Jeffrey had to be comfortable with the directors’ decision to not produce general purpose financial statements.)

If a charity, is their information on the ACNC Register complete / correct?

  • Not quite – ‘General community in Australia’ is not correct as ‘Who the Charity Benefits’.
    • If by ‘Other Name(s)’, the ACNC means trading and business names, then the two that IJMA have here don’t fit the bill.

What choices do you have in how your donation is used?

  • None
    • Ministry comment: ‘Donations given online are directed to the area of greatest need, however IJM Australia is happy to speak to donors interested in supporting particular areas of IJM’s global work, for example supporting a particular casework type, the work of a specific field office, or providing support for specific operational or other expenses.’

Where were your (net) donations sent?

  • Other than ‘overseas’ and ‘Australia’, this is not disclosed in the financial statements[3].

Who are the people controlling the organisation?

  • The website says these people.
  • The ACNC Register (under ‘Responsible Persons’) says the same except it adds Eric Boon:
  • The directors are responsible to the members of the association. At year-end there were 15 members (down from 17 two years ago). Directors must be members, so there is limited accountability here.

To whom are IJMA accountable?

  • On the webpage ‘Financials’ (and in the ‘2016 Annual Review’, under the heading ‘ACCOUNTABILITY’), IJMA say that
    • IJMA Australia adheres to the highest standards of accountability, working diligently to ensure that funds are allocated wisely in order to bring the greatest tangible relief to victims of oppression. An all-volunteer Board of Directors sets policies and procedures and monitors the budget and expenditures. In addition, an independent accounting firm conducts an annual audit to verify that IJMA Australia complies with all generally-accepted accounting principles and is a good steward of its financial resources.
      • The annual financial audit has nothing to say about being ‘a good steward’.
  • As a charity, IJMA is accountable to the ACNC.
  • As a company, IJMA is still accountable for some things to ASIC.

 

 

  1. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  2. The register of Victorian licensed fundraisers says that ‘Administration expenses’ is 0% – clearly a mistake.
  3. The register of Victorian licensed fundraisers says that IJMA is the beneficiary of its work‘ and that ‘Proceeds distributed to beneficiary’ is just 1%.

African Enterprise Ltd: charity review

A charity review of African Enterprise Ltd (AEA) as an organisation that seeks donations online and is a member of Missions Interlink[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

I sent them a draft of this review. The Executive Director, Ben Campbell, responded the same day (just like last year), saying ‘Thank you for your commentary which continues to sharpen our focus on good reporting to our supporter community.’  Plus, he supplied some specific comments, which have been included below, and the following general comment:

The work of mission and development in Africa is dependent on the wise stewardship of resources within our care.  Following the investment AE made to connect with new supporters in 2016, in 2017 we worked on new strategies to increase our efficiencies, engagement and improving the giving ratio which has been reflected in the latest results (to be uploaded in April 2018). We would like to thank our supporters for making a tremendous difference in Africa. Their support of this evangelistic mission in partnership with churches in the cities of Africa has seen 94,000 make a decision for Christ in 2017 and over a million hear the Good News of Jesus.   Thank you. 

Is AEA registered?

  • As a charity, yes.
  • AEA is a public company, a company limited by guarantee.
  • It uses the names AE Australia on Facebook and Instagram, African Enterprise Australia on Facebook , Vimeo and YouTube. and African Enterprise on the website.
    • To omit ‘Ltd/Limited’ when using its name, it needs to have specific provisions in its constitution. These are absent.
    • It doesn’t have any of the above names registered as business names.
    • It has registered African Update and African Harvest.
  • AEA operates – per the ACNC Register – throughout Australia.
    • It has a fundraising licence wherever it might require one.

What do they do?

  • Contrary to what it says on the website, AEA is not directly involved in Africa:
    • ‘As a support region our core purpose is to raise the requisite resources to finance and equip the work of all our brothers and sisters in Africa who are involved in evangelising the cities of Africa in word and deed in partnership with the church. We seek to inform, inspire and engage new generations of supporters to partner with African Enterprise to pray and financially give to the Ministry’.
      • Ministry comment: ‘In terms of what we do, there is an aspect of supporting Africa directly through this office through IT administration, strategic support and via specific investment from some supporters in response to certain needs. I have also been involved in both mission in Ghana and strategic support in Zimbabwe and the Chairman is also directly supporting strategy in Africa through the International Board.’
  • The financial statements consolidate the figures for a New Zealand charity, African Enterprise New Zealand Limited, and it appears that AEA also controls the African Enterprise presence in Hong Kong, but these connections are not explained anywhere.
    • Ministry comment: With regard to Hong Kong, there is no office there, however a number of supporters there whom we visit from time to time. ‘

Do they share the Gospel?[2]

  • No (they raise money for those that do).

What impact are they having?

  • Nothing systematic found on AEA’s impact.
  • There is a regular report on ‘mission impact’ in Africa on the website. Here’s an example:

  • Nothing systematic found for the development work.
    • Ministry comment: ‘As we are a major supporter of mission in Africa, the mission impact we have here in Australia is significant as we make it possible for the missions to occur through both prayers and financial support.  We also liaise with supporters with particular interests in projects that they have a direct influence on within Africa.  We also support the visits of African team leaders to help educate supporters/people on mission impact directly.’

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • There is a figure for ‘Administration’, but this excludes many expenses that only indirectly benefit the African beneficiaries.
  • If we assume that the impact is represented by the amount shown for ‘Overseas projects’, then then it cost AEA $904K to send $1.21 m. This is 43% of expenses (compared to 34% last year).
    • There is no explanation for this large increase.
      • Ministry comment: There was additional investment in campaigns to drive a greater awareness of the ministry in Africa during 2016.  This investment was scaled back in 2017.
  • You might ask them why it wouldn’t be more efficient for you to send your donation direct to Africa.

Do they pay their board members?

  • This is not prohibited by the constitution.
  • Note 4 to the financial statements says that they don’t get paid.
  • There is insufficient disclosure of expenses to check.

Can you get a tax deduction?

  • Not to AEA itself, but to the fund it operates, African Enterprise Aid and Development Fund.

Is their online giving secure?

  • Although the web address has a ‘https’ prefix, instead of a green padlock there is a warning that ‘Your connection to this site is not fully secure’.
    • Ministry comment: ‘There should always be a locked button to give via the website. The SSL certificate is in place and supporters should have confidence that their donation remains secure.’
      • Reviewer response: As I showed Ben – no ‘locked button’:

What choices do you have in how your donation is used?

  • ‘Missions’
    • ‘If you have a specific mission in mind, please add this in the ‘comments box’.’
  • ‘Aid and Development’

Is their reporting up-to-date?

  • Yes (five months after year end, a month earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • AEA are still reporting the financial information of the group, not for AEA.
    • Even ignoring that, some of the financial figures given do not match those in the financial statements.
    • The activities are not those of AEA, but those of African Enterprise globally.
    • No outcomes are reported.
    • Neither the states nor the countries that are listed match those listed on the ACNC Register.
    • One business name is missing, and the other is not recorded correctly.
      • Ministry comment: ‘Thank you for drawing the various matters to my attention and I will review the items listed in the interests of seeing correct alignment.’
  • Financial Report 2016
    • There is still no related parties’ disclosure.
    • In consolidated accounts it is conventional to give summary financial information for the holding company. This is again absent.
    • ‘Unsecured interest-free loans’ are still incorrectly classified as ‘Trade and other payables’ (should be ‘Borrowings’).

What financial situation was shown in that Report?

  • Another deficit was recorded this year (5% of revenue compared to 6% last year).
    • Ministry comment: ‘Please note that the deficit was recorded in 2016 as a result of drawing on strategic reserves, so a minimum reserve is maintained. For 2017, we have recorded a breakeven result and have not tapped into reserves.’
  • ‘Fundraising costs’ were 21% of expenses – up from 16% last year.
  • Employee benefits expenses was 24% of the total.
  • Working capital (current assets less current liabilities) is strongly positive.
  • There are minimal long-term liabilities, so long-term financial structure is sound.

Where were your (net) donations sent?

  • Other than overseas, this is not disclosed.

What did the auditor say about the last financial statements?

If a charity, is their page on the ACNC Register complete/correct?

  • Did AEA send money to all 14 of these countries, including Hong Kong and New Zealand?
    • Ministry comment: ‘Donations are supplied from NZ and Hong Kong for Africa, and not sent there. This information will be reviewed on the site.’
    • Despite the impression that you may get from AEA’s materials, the African Enterprise organisation in New Zealand is not part of AEA, but a separate charity, with a separate board of directors.
  • The business name that is shown is African Harvest, and one is missing.

Who are the people controlling the organisation?

  • The website shows them here.
    • It says there are ten but only shows eight. Something to do with the New Zealand charity?
      • Ministry comment: There was a recent change in directors and some of the website information needs to be updated as a result.
  • The ACNC Register (under ‘Responsible Persons’), has nine, with Benjamin Campbell and Stephen Thomas additional and John Hanne missing compared to the website list (assuming Chris Siriweera is the same person as Ananda Siriweena):

To whom is AEA accountable?

  • As a charity, to the ACNC.
  • As a company, to ASIC.
  • Although not mentioned on the website, AEA is an Associate member of Missions Interlink. Missions Interlink has an accountability regime[1]
    • For one opinion on the strength of that accountability, see the section Activities in this review.
  • Although AEA operates an overseas aid fund, they are not a member of the Australian Council for International Development (ACFID).

 

 

  1. Their link is to the international organization, not AEA.
  2. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

Who should be running a Baptist church?

Should a Baptist church choose to incorporate as an association[1], it is required to have a committee. The Act under which it will incorporate[2] says that this committee, ‘has the management of the association’.

If, as is likely, the church wants to be faithful to the beliefs and practices traditionally practised by Baptists, then it will have two ‘offices’: ‘pastor’ (elder) and ‘deacon’[3].

If they don’t want to have two separate churches, one Biblical and one secular[4], the question then becomes: how do they marry what they should do as Baptists with what they should do as an incorporated association?

As an incorporated association, the church should be managed by the committee. Some may think that ‘management’ is meant in the sense of ‘administration’. But the Model Rules, the rules that apply if an association doesn’t make up its own, make it clear that the powers of the committee extend well beyond administration:

With the Model Rules requiring only one general meeting in a year (the Annual General Meeting), the leadership of the association clearly rests with the committee.

So, to match that in the church, they would be looking for those who, Biblically, are to lead. And of the two offices required, elders and deacons, that is clearly the elders:

The elders who direct the affairs of the church well are worthy of double honor, especially those whose work is preaching and teaching [1 Timothy 5:17, NIV].

5 The reason I left you in Crete was that you might put in order what was left unfinished and appoint[a] elders in every town, as I directed you. 6 An elder must be blameless, faithful to his wife, a man whose children believe[b] and are not open to the charge of being wild and disobedient.7 Since an overseer manages God’s household, he must be blameless—not overbearing, not quick-tempered, not given to drunkenness, not violent, not pursuing dishonest gain. 8 Rather, he must be hospitable, one who loves what is good, who is self-controlled, upright, holy and disciplined. 9 He must hold firmly to the trustworthy message as it has been taught, so that he can encourage others by sound doctrine and refute those who oppose it. [Titus 1:5-9, NIV].

To the elders among you, I appeal as a fellow elder and a witness of Christ’s sufferings who also will share in the glory to be revealed: 2 Be shepherds of God’s flock that is under your care, watching over them—not because you must, but because you are willing, as God wants you to be; not pursuing dishonest gain, but eager to serve;[1 Peter 5:1-2][5] (emphasis mine).

Therefore, the committee should be composed of elders. And because deacons have a quite different role in the church, freeing the elders to do their ‘job’[6], that is, lead, there should be only elders on the committee.

That’s the theory, but what about the practice? As a test I looked at the constitutions of the Baptist churches incorporated in the ACT.

Belconnen Baptist Church Inc (Mosaic Baptist Church)

Their committee is called ‘the Church Board’[7]. It consists of the Senior Pastor (ex-officio) plus ‘at least 5 other church members who are: (i) at least 18 years of age; and (ii) have been an active member of the Church for at least the preceding six months.[8] No Biblical qualifications are required.

They do have (an unspecified number of) elders, but they have only an advisory role.

Brindabella Baptist Church Incorporated

The committee has to have ‘at least 3 church members[9]. To be eligible, the person must be at least 18, and ‘have been an active participant in the life of the church for at least 12 months.’[10] No Biblical qualifications are required.

Elders are not mentioned.

Canberra Korean Baptist Church Incorporated

Their committee is the one that’s in the Model Rules: four ‘office-bearers’ (president, vice-president, treasurer and secretary[11]), and ‘at least three ordinary committee members’, except that two people have to hold more than one office[12]. The Bible is not mentioned.

Emmanuel Independent Baptist Church

The Committee shall consist of a. the officers of the Association; and b. other members…’ [Article 25]. The ‘officers’ are ‘a Chairman who shall be the Pastor of the church’, Deputy Chairman, and a ‘Treasurer-Secretary’ [Article 24]. The Bible is not mentioned.

Northpointe Baptist Church Incorporated[13]

Article 5, ‘Officers’, discusses elders, pastors, ‘deacons (deaconesses)’, and Treasurer. The committee is mentioned just once. The use of the term ‘Leadership Team, again just once[14], and the use of the statutory term ‘officers’ strongly suggests that all these people serve on the committee.

Elders must satisfy the requirements in 1 Timothy 3:1-7 and Titus 1:6-9. ‘Pastors are Elders with a special pastoral calling or gift[15] [Article 5, page 4]. For deacons/deaconesses, the reference to Acts 6:1- 7 when explaining their role, implies that the qualification for role is that they ‘are known to be full of the Spirit and wisdom’.

Tuggeranong Baptist Church Incorporated

‘We believe that the church should be headed by a male Pastor who will be assisted in church government by qualified men and/or women called Elders whom we empower to exercise Godly leadership over us[16].

A subsequent clause links this belief with the association requirement for a committee:

The committee of the association shall consist of, at a minimum, the senior pastor and three elders[17].

There is no age or length of attendance requirement; both are subsumed in the Biblical qualification required:

All Elders must be chosen and accepted on the basis of the Scriptural qualifications laid down in 1 Timothy 3 and Titus 1:5-9, and must have been members for sufficient time to have demonstrated their gifts and character[18].

There is a requirement for deacons[19], but although they ‘serve for a Term with the Elders’[20], the fact that their responsibilities are ‘delegated to them by the Eldership’[21] , and that their nomination ‘must be confirmed by the Eldership’[22] is against any interpretation that they serve on the committee with the elders.

Valley Baptist Church

The committee consists of ‘the pastor and deacons’[23]. The pastor must meet the requirements of 1 Timothy 3:1-7, and the deacons the requirements of 1 Timothy 3:8-13 plus the ‘Teacher’s and Officer’s Covenant’ (which is included in the constitution)[24].

Conclusion

Based on this sample, Baptist churches, at least in the legal expression of how they govern, show little adherence to the Biblical injunction that it is elders who should lead the church.

 

 

  1. It is far from automatic that if it does, it should choose an association rather than a company –
  2. In the Australian Capital Territory, the ASSOCIATIONS INCORPORATION ACT 1991 – SECT 60
  3. See for instance, here.
  4. As Valley Baptist Church Incorporated seems to be trying to implement with this provision under ‘Qualifications of Officers’: ‘Trustee/Committee members: these officers are solely for the purpose of incorporation of the church. The Pastor shall act as the Public Officer of the church along with two appointed committee members.’ [Section 2, their constitution].
  5. There is even Biblical support for the elders to lead in money matters too: ‘The disciples, as each one was able, decided to provide help for the brothers and sisters living in Judea. 30 This they did, sending their gift to the elders by Barnabas and Saul’ (emphasis mine) [Acts 11:29-30].
  6. 1 Timothy 3:8–13
  7. Clause 2.2
  8. Clause 10
  9. Clause 7.2.1
  10. Clause 7.2.2
  11. There is no requirement under the Act to have any particular offices, e.g. President, Treasurer etc [Associations Incorporation Act 1991 – Notes, Dictionary.
  12. Clause 17
  13. My wife and I attend this church. We are not members of the Association.
  14. Article 5, page 3.
  15. Article 5, page 4.
  16. Clause 3)b). This clause goes on to say that ‘The Elders and the Fellowship are served by qualified men or women called Deacons.
  17. Clause 6)a)
  18. Clause 7)b)i)
  19. Clause 8
  20. Clause 8)a)
  21. Clause 8)b)
  22. Clause 8)c)
  23. Article IV, Section 2
  24. Article VIII, Section 2

Westminster Presbyterian Church Presbytery of Western Australia: a charity review

A charity review of Westminster Presbyterian Church Presbytery of Western Australia Inc (WPCWA) an organisation that appears to be the one that is listed as a member of Missions Interlink[1].

Are they responsive to feedback?

  • I sent them a draft of this review. They….did not respond.

Is WPCWA registered?

  • As a charity, yes.
  • WPCWA is a Western Australian incorporated association (A1014600W)[2].
  • If its website is wpc.org.au[3], then it is using the names WPC Australia and Westminster Presbyterian Church in Australia. It holds no business names.
  • WPCWA operates – according to the ACNC Register – in Australian Capital Territory, New South Wales and Western Australia, plus overseas in Vanuatu.
    • It does not have the required registration (an ARBN) to carry on business outside Western Australia.
    • There is no indication that it does any fundraising, so the question of state fundraising licences does not arise.

What does it do?

  • The Annual Information Statement (AIS) 2017 says that
    • We support local churches in various ministries. We screen new ministers and churches. We seek to develop new churches. We are supporting a couple of overseas missionaries.
    • ‘Local’ is not Western Australia: the first of the ‘Presbytery’s Objects in the constitution is
      • to assist congregations affiliated with the Westminster Presbyterian Church in all States and Territories except Queensland to…

Do they share the Gospel?[4]

  • No.

What impact are they having?

  • No information found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • No Financial Report 2017 has been lodged (see below), and it is not possible to estimate ‘administration’ from the four expenses disclosed in the AIS 2017.

Do they pay their board members?

  • Such payments are not prohibited by the constitution.
  • Insufficient financial information is provided to check.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

Is their reporting up-to-date?

  • Yes.
    • Despite an AGM that was held in August, the AIS was not lodged for another five months, a week before the deadline, and a month later than last year.
    • If you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over seven months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Almost – no outcomes are reported.
  • Financial Report 2017: Yes
    • Because of their size, they don’t have to lodge one.
    • However, their Associate membership of Missions Interlink requires them to “have available for [their] members and supporters a clear and appropriate financial statement which has been approved by its auditor.” No such statement has been made public.

What financial situation was shown by that Report?

  • From the AIS 2017:
    • A surplus of $6K on revenue of $246K.
    • ‘Employee expenses’ were 93% of the total.
    • Liabilities are 87% of assets.

What did the auditor say about the financial statements?

  • If there was an audit, it is not available to the public without charge.

If a charity, is their information on the ACNC Register complete?

  • Almost – ‘Who the Charity Benefits’ is blank. (So is ‘Website’, but that’s not compulsory.)

What choices do you have in how your donation is used?

  • NA

Where were your (net) donations sent?

  • Presumably the $245K ‘Donations and requests’ (AIS 2017) came from affiliated churches.
  • There is no disclosure of where the $5K of ‘Grants and donations…’ went.

Who are the people controlling the organisation?

  • Per the ACNC Register (under ‘Responsible Persons’):
    • John MacRae
    • Simon Van Bruchem
    • Ray Wilson
  • The committee is responsible to the members of the association. The number of members is not disclosed.

To whom are WPCWA accountable?

  • As a charity, to the ACNC.
  • As an association, to the Western Australian regulator of incorporated associations.
  • If they are indeed the member referred to as Westminster Presbyterian Church of WA’, then WPCWA is accountable to Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. The membership is listed as being in the name ‘Westminster Presbyterian Church of WA’. The link though is to a Presbyterian church at Bull Creek. That church has asked Missions Interlink to remove that link (email from them).
  2. Not to be confused with Westminster Presbyterian Church, another Western Australian incorporated association (A08200735). (But with no ABN.)
  3. Despite WPCWA’s name, it operates in two other states.
  4. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

Hillcrest Christian College Limited: mini-charity review

Mini-charity review of Hillcrest Christian College Limited (HCC), an organization that is connected, through the cross directorship of Jame Lewis, to the CMA Standards Council, a body that accredits those organisations who pass its ‘Nine Principles of Ministry Accountability’. HCC is not accredited.

(Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • HCC does not invite feedback and complaints from other than students, parents and employees.
  • I sent them a draft of this review. They…did not respond.

Is HCC registered?

  • As a charity, yes.
  • HCC is a public company, a company limited by guarantee[1].
  • Although it does not have the provisions in its constitution to allow it to omit ‘Ltd’/‘Limited’ from the end of its name, it has Hillcrest Christian College registered as a business name.
  • HCC operates – according to the ACNC Register – only in Queensland.
  • Although it conducts fundraising, it doesn’t have a licence. Perhaps it believes that it is because it is a religious order, or because all fundraising is done by a parents and citizens association (two of the exemptions)?

What do they do?

  • See the video on the homepage, then ‘Our College’ in the main menu.

Do they share the Gospel?[2]

  • Yes. One of HCC’s ‘Cornerstones’ is ‘Evangelistic Outreach’:
    • The first cornerstone of the foundation is our belief that the College has a spiritual ministry to its students and an evangelistic outreach into the community. The most important subject that is taught every day is God and the most important book that is used is the Bible.

Our objectives are to be good stewards of the time that the Lord has given us, to minister to the children in the college, to bring each child to a personal saving knowledge of Jesus Christ, and to train them in the fundamental truths of the faith.

What impact are they having?

  • Nothing systematic found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • With $18.79 m expenses divided into only three figures (see below), there is no way of even estimating this.

Do they pay their board members?

  • This is not prohibited by their constitution.
  • There is insufficient disclosure of the expenses to check for a payment.

Can you get a tax deduction?

  • Not to HCC, but the ABN record says that you can if you donate to either of its two funds, Hillcrest Christian College School Building Fund, or Hillcrest Christian College Ltd Foundation Scholarship Fund.
  • From the lack of mention on the website, though, it appears that neither are active.

Is their online giving secure?

  • NA – not offered.

Is their reporting up-to-date?

  • Yes (four months after their year-end; ten days earlier than last year).
    • But if you are considering a large donation, I would ask for audited financial statements (see below), and more up-to-date financial information – the accounts are for a year end that is now over 13 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Type of financial statement’ and ‘Financial statement consolidated with more than one entity?’ are blank. Or is that a consequence of the ACNC’s special treatment of non-government schools (see below)?
    • No outcomes are given.
  • Financial Report 2016: Yes
    • The Register says that one was lodged but in fact it is a single sheet produced by the ACNC, not HCC, that says
      • The ACNC receives financial information for this school from the Department of Education and Training and publishes it in Section E: financial information of the Annual Information.
    • So not only no financial statements but no audit report. And this for a charity with revenue of $22.14 m. Contact the school if you want more.

What financial situation was shown by that Report?

  • From the AIS 2016 (see above):
    • From government: $12.52 m.
    • Total revenue: $22.14 m.
    • Employee expenses: $12.35m. 66% of expenses.
    • Interest: $334K. 2% of expenses.
    • Surplus: 15% of revenue. Why is it this high?
    • Current liabilities are 1.4 times current assets. Not so good.
    • No non-current loans – why then the interest paid?
    • Long-term financial structure, because of $30.08 m in non-current assets (presumably mostly land and buildings), is sound.

What did the auditor say about the financial statements?

  • NA. The system of reporting for non-government schools like HCC effectively says to you, ‘Trust me’.

If a charity, is their information on the ACNC Register complete / correct?

  • Almost. ‘Phone’ and ‘Website’ are blank. (Neither are compulsory.)

What choices do you have in how your donation is used?

  • NA – none sought

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • The website says these people.
    • The introduction to the list says that there should be seven members, but then lists eight.
  • The ACNC Register (under ‘Responsible Persons’) has the addition of Jame Lewis, and doesn’t have Nadine Harvey and Alan King.
  • The directors are responsible to the members of the association. The constitution provides that they must be members of Reedy Creek Baptist Church. The number of members is not disclosed, so we cannot assess the accountability possible via the members.
  • It’s an unusual board though – itfollows a Carver Model of Governance.’

To whom are HCC accountable?

  • HCC does not mention accountability on its website.
  • It gets government funding, so there is accountability there.
  • As a charity, it is accountable to the ACNC.
  • As a company it is accountable to ASIC.

 

 

  1. Not, as they say on the ABN record, an ‘Other Incorporated Entity’.
  2. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

Westminster Presbyterian Church Bullcreek Inc: mini-charity review

Mini charity review of Westminster Presbyterian Church Bullcreek Inc (WPCB).

Are they responsive to feedback?

  • If sent them a draft of this review. They did not answer when I asked them whether they intended to suggest corrections and submit comments.

Is WPCB registered?

  • Yes, as a charity.
  • WPCB is a Western Australian incorporated association (A0770077W).
  • Registered for GST.
  • No business names are held. It should therefore not be trading under the names WPC Bull Creek or Bull Creek WPC.
  • It likely does no fundraising, so the lack of fundraising licences is to be expected.

What does WPCB do?

  • The things that you would expect of an institutional ‘church’. See www.wpcbc.net.

Do they share the Gospel?

  • Yes

What impact are they having?

  • No information found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If the impact they are seeking is what’s expressed in ‘Article III – Object’ in the constitution, the expenses are not classified to allow the calculation of a figure for ‘administration’.

Do they pay their board members?

  • This is not prohibited by their constitution.
  • The expenses are not disclosed sufficiently to check for such payments.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

What choices do you have in how your donation is used?

  • General giving “Tithes & Offerings”
  • Missions & Apprenticeship Programme’

Is their reporting up-to-date?

  • Yes (in a relatively short time after their year-end, two months; but ten days later than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Three of the figures in the ‘Comprehensive Income Statement summary’ do not match those in the financial statements.
    • No outcomes are reported.
    • ‘WA incorporated association number is blank.
  • Financial Report 2017: No
    • With a professional staff of 13 and earning $1.22m in revenue, special purpose financial statements are not appropriate.
      • The elders do not explain why they made this decision.
    • The ‘Statement by Session’ does not meet ACNC requirements.
    • No ‘Other comprehensive income’ is disclosed.
    • There are several significant items under ‘Expenditure’ that are not explained.
    • All the cash did not come from ‘customers’.
    • The valuation basis of the non-current assets is not disclosed.
    • The distinction between ‘Land’ and ‘Church property’ is not explained.
    • Many of the liabilities, at least based on their name, do not meet the definition of a liability.
    • ‘Prepayments’ are an asset, not a liability.
    • The source of the ‘Borrowings’ is not disclosed.

What financial situation was shown in that Report?

  • The deficit as a percentage of revenue was still negative, but declined from 1% to 1/2%.
  • Employee expenses were 48% of expenses.
  • Current assets as a multiple of current liabilities declined from 2 to 1.7.
  • Holding property ensures that the long term financial structure is sound.

What did the auditor say about the last financial statements?

  • The auditor, Geoffrey Carslake, for Shreeve & Carslake, issued a ‘clean’ opinion.
  • Before you conclude on how much comfort you should take from this opinion, please
    • read on the meaning of ‘clean’ here and here, and
    • re-read the section ‘Financial Report 2017’. (To do the audit, Geoffrey had to be comfortable with the elders’ decision to not produce general purpose financial statements.)

If a charity, is their page on the ACNC Register complete/correct?

  • Not quite – ‘Who the Charity Benefits’ is blank.

Where were your (net) donations sent?

  • The AIS 2017 shows that ‘Grants and donations made for use in Australia’ totalled $120K, and that the similar figure for overseas was $89K.
    • The combined figure is $53K short of ‘Missions’ in the expenses.
  • The destination of this money is not disclosed.

Who are the people controlling the organisation?

  • Not shown on the website, but here there are from the ACNC Register (under ‘Responsible Persons’):
  • All these people are elders of WPCB, and form the ‘session’ [Constitution, Article VI).

To whom is WPCB accountable?

  • As a charity, to the ACNC.
  • As an association, to the Western Australian regulator of incorporated associations.

Dignity Freedom Network Australia Ltd: mini-charity review

Mini-charity review of Dignity Freedom Network Australia Ltd (DFN), an organisation that seeks donations online and is an Associate member[1] of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Is it responsive to feedback?

  • DFN claim to be ‘committed to accountability and transparency in all practices’.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is DFN registered?

  • As a charity, yes.
  • DFN is a public company, a company limited by guarantee.
  • Its name:
    • They changed their name from Dalit Freedom Network Australia Ltd in October 2017[2]. There is no explanation for this change either on the website or in the Financial Report 2017[3].
    • DFN does not appear to have the provisions in its constitution necessary to permit it to omit ‘Ltd/Limited’ from the end of its name.
    • It does not have any business names registered[4].
    • Because of the above, it does not have the necessary permissions to publicly use Dignity Freedom Network or Dignity Freedom Network Australia (its website), or DFN Australia and New Zealand (Facebook)[5].
  • In its AIS 2017 it said it intended to fundraise in four of the five states where, per the ACNC Register, it operates. All have a fundraising licensing regime for charities. The AIS 2017 also says that a licence is held in Victoria, but this does not agree with Victoria’s list. No licence is held in the other states. Perhaps the AIS 2017 information is a mistake, and DFN believes that it is exempt everywhere?
  • DFN, per the ACNC Register, operates overseas only in India. But this is only in the sense that this is where your money is sent.

What do they do?

  • Ignoring the fact that it combines Australia and New Zealand, the ‘Company Overview’ on Facebook gives the right picture[6]:
    • We are the Aus/NZ branch of Dignity Freedom Network, a global not-for-profit organisation that works in India to end caste based (sic) discrimination.
      Here down under we work to raise awareness and advocate for India’s oppressed, while raising funds to support our sustainable development programs.
  • What is the relationship with the New Zealand organization?
  • DFA is a ‘Public Benevolent Institution’.

Do they share the Gospel?

  • No
    • DFN have not selected ‘Advancing Religion’ as an ‘Entity Subtype’.

What impact are they having?

  • There is no information on the website about impact (nor outcomes or results).

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • ‘Aid and development’ projects is only 37% of expenses. ‘Employee benefits expense’ is larger at 44% of expenses.
  • This seems quite different to what they claim on the website:
    • ‘14. Eighty percent of gifts received for a specific project are applied directly to that project and 20% towards administration. Eighty percent of sponsorship support is applied to the education program and 20% towards administration.’
  • The implication that the cost of administration goes up proportionally – whatever the proportion – is a licence to make a profit on administration.

Do they pay their board members?

  • The constitution does not prohibit this.
  • The financial statements do not say one way or the other.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • The ‘Donate’ page says ‘100% Secure’, but this claim is still not supported.

What choices do you have in how your donation is used?

  • It’s not clear. On the ‘Donate’ page you enter an amount etc. but there is no purpose specified. And a button underneath says ‘Sponsor a child’. But on the Home page, there is ‘Donate’, ‘Free a Child’, and ‘Free a Woman’. So, I’d say general purposes and sponsorship of either a woman or a child.

Where were your (net) donations sent?

  • This is not disclosed.
  • We know that they send the money to India, but without further information we can’t check the FCRA returns submitted to the Indian government.

Is their reporting up-to-date?

  • Yes (five months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • They don’t do the things they said they do here.
    • ‘Type of financial statement’ is incorrect.
    • Three of the five figures under ‘Gross Income’ are incorrect.
    • They are not registered as a fundraiser in Victoria.
  • Financial Report 2017: No, not a true and fair view.
    • The audit report has been omitted from the Report.
    • There is no explanation of the relationship with the New Zealand organization.
      • Is it the reason for the unexplained $24K revenue item, ‘admin & management fees received’?
    • Special purpose financial statements, the ones that do not have to comply with all the Accounting Standards, are not appropriate for an organization seeking donations from the public, operating in five states, receiving more than half a million dollars in donations, and having a professional staff of five.
      • The directors do not say why they believe the entity to be ‘not a reporting entity’.
    • 98% of what is recorded as liabilities, $47K, are ‘Project funds unpaid’. Such funds are not normally liabilities.
    • A ‘Cost of sales’ of $184K makes no sense with ‘sale of goods’ of $1K, and zero inventory.
    • There is no mention of the change of name from ‘Dalit’ to ‘Dignity’.
    • The fact that the figures are not for the usual 12 months is mentioned only in one part of one Note.
    • The is no explanation for the existence of not insignificant ‘Finance costs’ when no money is owed.

What financial situation was shown in that Report?

  • No obvious issues.

What did the auditor say about the last financial statements?

  • There is an auditor – Kar Seng Chan of KSChan & Co – but no audit report.

If a charity, is their page on the ACNC Register complete/correct?

  • Almost – ‘Website’ is still blank. (The ACNC says that it is not compulsory.)

Who are the people controlling the organisation?

  • Not shown on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
  • If the Rodwells are a couple, then with only two other directors, it would be valid for you to question the governance of this charity.

To whom is DFN accountable?

  • They say, on the website, that
    • ‘12. To demonstrate our commitment to transparency and accountability, Dalit Freedom Network Australia posts a variety of information about the organisation on our website including: our financial statements and other related material.’
      • There are still no financial statements on the website.
  • They are accountable, as a charity, to the ACNC.
  • And to ASIC as a company.
  • Their Associate membership of Missions Interlink means that they must comply with some standards.
    • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. Under its old name.
  2. There is also an incorporated association named Dalit Freedom Network Australia Inc. This entity has no ABN. Is it a forerunner of the superseded company name?
  3. Perhaps it is something to do with who the Dalits are, maybe even political?
  4. Dalit Freedom Network Australia Inc has the name Dalit Freedom Network registered.
  5. The New Zealand organization, Dignity Freedom Network New Zealand, is still not a registered charity.
  6. Both the ‘About’ page on the website, and the AIS 2017, combine what DFN does with what is done overseas by the organisations to whom it sends your money.

ACC International Missions Ltd: mini-charity review

Mini-charity review of ACC International Missions Ltd (ACCIM), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • ACCIR welcomes it:
    • ACCI recognises that listening to and responding to feedback, concerns and complaints is integral to our commitment to achieving the high standards and ensures accountability to all stakeholders. Complaints or feedback can be submitted to the CEO of Operations via the below contact details or to another ACCI employee, field worker or strategic partner.
  • When sent a draft of this review, they…did not respond. [Last year: did not respond.]

Is ACCIM registered?

  • As a charity, yes. (But as Acc International…).
  • As a public company, a company limited by guarantee.
    • Not, as the ABN record still says, an ‘Other Incorporated Entity’.
    • It has the necessary provisions in its constitution to allow it to omit ‘Limited/Ltd’ on the end of its name.
  • It has two business names, ACCI Missions & Relief, and Australian Christian Churches World Missions. (The second is not shown on either the ABN record or the ACNC record.)
  • ACCIM operates in all six states that have a fundraising regime for charities, and has an invitation to give on the internet. They do not explain why they hold no fundraising licences.

What do they do?

  • ACCI Missions is the missionary sending and support agency of the Australian Christian Churches movement (link added).
    • This is on an ‘About’ page on ACCIM’s website (www.accim.org.au) that starts by describing the work of the unregistered charity ‘ACCI’. Further down it identifies ACCI as being composed of ACCIM and another charity, Acc International Relief Inc. (Relief). (Relief also has its own website, www.accir.org.au, a website that does not include information about ACCIM.)
      • The combination of the two ‘Acc International’ organisations has been formalised in a business name for ACCIM, ACCI Missions & Relief. See, for instance the ‘Donate’ page on the ACCIM site.
      • The website uses the name ACCI. However, this is a business name held by the Australian Carpet Cleaning Institute Pty Ltd (www.asic.gov.au).
  • Per the Annual Information Statement (AIS) 2016, the same description as last year:
    • The principal activities of ACC International Missions Ltd during the financial year were: • To recruit, enable, support and send field workers to Australia and foreign countries to establish self-governing, self supporting and self propagating (sic) churches and preach the Gospel in Australia and other nations around the world; • To provide pastoral support, direction, vision and strategy for field workers as they prepare for ministry and minister overseas; • To work in synergy with local congregations within the Australian Christian Churches movement and assist them to fulfil the Company’s vision; and • To otherwise fulfil and follow the missionary objects of the Australian Christian Churches.

Do they share the Gospel?[1]

  • Yes

What impact are they having?

  • Nothing systematic found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If we define ‘direct’ as ‘Disbursements to missionaries and projects’, then ‘administration’ is 22% of expenses. Making the cost object smaller will increase this percentage, e.g. by recognizing that there is overhead in the projects in the overseas country.

Do they pay their board members?

  • This is not permitted by the ACCIM constitution.
  • The expenses are not disclosed sufficiently to allow a check.

Can you get a tax deduction?

  • No
    • But their website also collects for Relief, a separate charity, as well. Donations to Relief are tax deductible.

Is their online giving secure?

  • Security is not mentioned.

Is their reporting up-to-date?

  • Yes (four and a half months after their year-end, one and a half months earlier than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite no outcomes are given.
  • Financial Report 2016: Probably. But
    • It is hard to see that a report that makes no mention of (a) the organization the objects of which it is required to follow, Australian Christian Churches, and (b) the organization with which it shares a business name and a website, Relief, can be judged as showing a true and fair view.

What financial situation was shown by that Report?

  • Last year’s deficit of less than 1% of revenue was increased to 3%.
  • Less than two and a half months of revenue is held in ‘Cash and cash equivalents’ plus ‘Financial assets’.
  • Both short-term and long-term financial structure are, based on this Report, sound.

Where were your (net) donations sent?

  • The Statement of Profit or Loss and Other Comprehensive Income just says ‘Disbursements to missionaries and projects’ $2.55 m.

What did the auditor say about the last financial statements?

  • The auditor, Jeffrey Tulk, for Saward Dawson, gave a ‘clean’ opinion.
    • To take the right amount of comfort from a ‘clean opinion’, please read here and here.

If a charity, is their information on the ACNC Register complete/correct?

  • No
    • One business name, Australian Christian Churches World Missions, is missing.
    • For the directors, which is correct, website or ACNC Register?

What choices do you have in how your donation is used?

  • Many – via a visually confusing set of pages and tiles:
    • The first set of tiles:
      • Donate’
      • Middle East Crisis Appeal’
      • ‘OneLife Partnership’
        • A form for churches
      • Make a Tax-Deductible Donation’
        • This takes you to Relief’s website. (ACCIM does not have tax-deductible status.)
      • Event Offering’
        • This is an ‘ACCI’ event, i.e. a joint ACCIM and Relief event.
    • The second set of tiles:
      • Regular Giving’
      • Support a Missionary’
        • A list of 55 individuals/couples
        • The list includes Relief’s workers
      • Make a Single Gift’
      • Current Appeals’
        • This takes you to Relief’s website. (ACCIM does not have tax-deductible status.)

Who are the people controlling the organisation?

  • Again this year, the listing under ‘Our Board of Directors’ on the website has only one name in common with the list under ‘Responsible Persons’ on the ACNC Register:

To whom are AC accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.  The ‘tick’ also means ACCIM’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • ACCIM claims that it ‘is an accredited member of Missions Interlink and operates in compliance with Missions Interlink Statements and Accreditation Standards.’ Membership confirmed.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • ACCIM is also accountable, as a company, to ASIC.

 

 

  1. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.