Entente Foundation: mini-charity review

Mini-charity review of Entente Foundation (EF), an organisation founded by Vanessa Hall (‘the Trust Lady‘ and Chair of the CMA Standards Council), and that invites the public to donate to it. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is it responsive to feedback?

  • They did not reply to my invitation to comment, sent on 21 March 2017.

Is it registered?

  • Yes, as a charity.
  • EF is a public company, a company limited by guarantee.
  • There’s also a private company with the name ‘Entente’, Entente Pty Limited.
    • This is the company that, per her LinkedIn profile, Vanessa has worked for since 2000.
    • A Google search on the company name leads to the website www.entente.com.au. This is headed ‘entente – international movement of trust’.
      • This is a movement led by Vanessa.
  • The same profile says that this movement ‘has both a for-profit and a charity’, so presumably these are Entente Pty Ltd and EF.
  • EF is registered as a fundraiser in the only state in which it says it operates, its home state, NSW. (Presumably it has been advised that its internet request for donations doesn’t qualify as ‘fundraising’ in any of the other six states that have a licensing regime. Not a position taken by all experts.)

What does EF do?

  • There’s a short description plus links to their programs, below the slider here.
  • The company’s single Object in its constitution is to
    • promote the prevention and control of human behavior that is harmful or abusive to human beings specifically emotional abuse, physical abuse, sexual abuse and substance abuse…[1]

Do they share the Gospel?

  • EF does not claim to be a Christ-centred organisation, either on its website or in its constitution.

What impact are they having?

  • Nothing systematic found.
    • Some indicators of a better functioning community after EF’s intervention are given at the end of this video.
    • They planned for an Annual Report for each year, but the last one is for two years ago.

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

  • The expenses are not classified to allow this calculation.

Can you get a tax deduction?

  • Not to EF itself, but to the fund that it runs, Building and Restoring Trust Gift Fund.
    • Its purpose is ‘the prevention or the control of behaviour that is harmful or abusive to human beings.’
      • This is the current description of what your money will be used for:
        • We desperately need funds to assist us in researching and developing programs and materials to help those who are broken and have forgotten how to trust. 

Is their online giving secure?

  • PayPal is used, so yes.

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

  • None

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Yes
  • Financial Report 2016: Yes. (Being a ‘Small’ charity, the report that was submitted was done so voluntarily.)
    • Given the strong connection with the company Entente Pty Limited (see above), a related parties Note should have been included.

What financial situation was shown in that Report?

  • The equity was reduced from $32K to $7K by a loss of $25K.
  • 95% of the expenses are in unexplained item ‘Other expenses’.
  • They operated this year without any non-current assets (office equipment etc).

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].

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

  • Not quite
    • They are long overdue in selecting an ‘Entity Subtype’.
    • ‘Phone’ and ‘Website’ are blank. EF has a website, and shows a phone number there.
      • I am waiting on the ACNC to tell me what in the ‘Charity Details’ section is compulsory.

Who are the people controlling the organisation?

  • The three ladies here.
  • And on the ACNC Register:
    • Dianne Beer
    • Vanessa Hall
      • Although not shown on this profile, Vanessa is the Chair of the ‘Standards Panel’ (or is it the ‘CMA Standards Council’?), a committee of Christian Ministry Advancement Ltd, an organisation that believes that
        • Christian organisations should be the standard-setters in terms of impeccable corporate behaviour.
          • The Panel’s mission is to ‘help build faith and trust in Christian organisations’, including by allowing organisations who are compliant with a set of standards, formed by the Council, to display the Council’s seal of approval.
    • Glenda Nixon
    • Glenda Nixon
      • I’d be surprised if this was not a duplicate.

To whom is EF accountable?

  • EF is also accountable to the ACNC.
  • And, as a company, to ASIC.

 

 

  1. Three of the activities listed under this object refer to ‘the Principal Object’. This is defined as ‘the Object in Clause 0, but there is no ‘Clause 0’.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Heart for Kids Australia Ltd: mini-charity review

Mini-charity review of Heart for Kids Australia Ltd (HFK), an organisation that is an Associate member of Missions Interlink and which invites the public, via the website linked from that membership, to donate to it.

Are they responsive to feedback?

  • After sending a draft of the review on 21 February, an email exchange with one of the ‘responsible persons’ led to an extension of the time to suggest corrections and offer comments to 10 March. I didn’t hear from him again.

Is HFK registered?

  • Yes, as a charity.
    • It appears that it has taken over another charity, Chinaheart International Incorporated (CI):
      • ‘ChinaHeart has become part of our new organisation, Heart For Kids. This is in response to a call to begin serving children in India and Indonesia as well as China.’
        • But CI, per the ACNC Register, doesn’t work in India and Indonesia, only in China.
    • HFK has yet to take advantage of the ACNC’s group reporting concessions.
      • Independent of this, expect to see 2017’s financial statements combining the two charities.
    • CI itself has a wholly-owned subsidiary, ChinaHeart International Aid Fund.
      • Although I have not included information about this charity below, it would need to be considered if you were considering involvement with HFK.
    • HFK is also connected with a business, LST Group (a business name belonging to The Trustee for the David Ryan Trust).
  • HFK is a public company, a company limited by guarantee.
    • CI is a New South Wales incorporated association (INC9884006).
  • No fundraising licence in its home state – or in any other state[1].
    • CI: the same.

What does HFK do?

  • There is no one clear statement but all the information is here.
  • An alternative way to get the answer to this question is to look at the ‘Donations’ page.
    • CI: the website address on the ACNC Register leads to the HFK website.

Do they share the Gospel?

  • 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?

  • The website talks about ‘ChinaHeart’, not HFK. It says that
    • ‘Our aim is to send 85% of your donation through to the children and families in our projects.  Traditionally we have been able to send 85% to 89% of donations.’
      • The 2016 Income Statement of ChinaHeart International Incorporated shows that ‘Project Payments’ were 76% of ‘Income’ other than ‘Miscellaneous Income’ and ‘Interest’. The previous year was 82%.

Can you get a tax deduction?

  • Yes
    • CI: No

Is their online giving secure?

  • eWay and PayPal are used, so yes.

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

  • Sponsor a Child in Need’
  • ‘Purchase an item’
  • ‘Donate’
    • where most needed’
    • ‘orphans’
    • ‘Doves Wing foster home’
    • ‘Morning Light Special Needs Centre’
    • ‘Christmas gifts for rural kids’

Is their reporting up-to-date?

  • Yes (seven months after their year-end, eight days before the deadline)
    • CI: the same

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Yes
    • HFK was only established in May 2016, so I’m not sure why the ACNC required an AIS 2016.
    • CI: Not quite: Their business name is missing, no outcomes are given, and isn’t the proceeds of fundraising part of ‘Donations and bequests’?
  • Financial Report 2016: Yes
    • One wasn’t required, either because of HFK’s small size, or because it was only established a month before its year-end.
      • The financial information in the AIS 2016 is all zeros.
    • Next year though, the combination of HFK and its subsidiary CI will mean that a Report will be required.
    • In addition, 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.”  So just ask.

What financial situation was shown in that Report?

  • NA
    • CI:
      • A deficit of 7% of revenue last year was repeated this year.
      • No non-current assets.
      • Minimal liabilities.

What did the auditor say about the last financial statements?

  • NA
    • CI: It was a review, and he gave a ‘clean’ opinion.

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

  • Almost – ‘Operating State(s)’ is blank.
    • CI: No:
      • They are long overdue in selecting an ‘Entity Subtype’.
      • Their business name is missing.
      • They only show two ‘Responsible Persons’.

Who are the people controlling the organisation?

  • The ‘leadership team’ is shown on the website, but the board members are not identified.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Poay Lee
    • David Ryan
    • Adam Tedja
      • Is it this Adam Tedja?
    • CI:
      • Ken Lee
      • David Ryan (as above)
        • Although there are nine directorships recorded for the name ‘David Ryan’, and the ACNC Register has only charities, three are in the HFK group, and he has no executive position outside HFK.

To whom is HFK accountable?

  • To Missions Interlink[2] via its an Associate membership.
  • HFK is also accountable to the ACNC.
  • And, as a company, to ASIC.
    • CI: to the ACNC and the New South Wales associations regulator.

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of that accountability, see the section Activities in this review.

Pipeline Ministries International Incorporated: mini-charity review

Mini charity review of Pipeline Ministries International Incorporated (PMI), an Associate member of Missions Link, and an organisation that provides an online donations facility.

Is it responsive to feedback?

  • The draft review I sent on 24 February started a conversation that culminated in a few minor changes and the comments included below.

Is PMI registered?

  • As a charity, yes.
  • Other registrations:
    • As a Victorian incorporated association (A0028363C).
    • It has no fundraising licence in its home state, or in any of the six others that have a licensing regime[1].

What do they do?

  • Generally: Under the pictures here.
  • More specifically, from the AIS 2016 (and with no intention of changing in 2017):
    • Pipeline raises funds in Australia through events such as trivia nights and garage sales and also from direct donations and sponsorships. This money is mainly used in the Philippines to support: – child feeding, – education of the less fortunate through child sponsorship and teachers’ salaries, – micros loans for small business, – emergency relief – community workers/pastors Pipeline works with a church organisation in the Philippines to carry these activities out. All work here and overseas is voluntary and sometimes dangerous. We travel to the Philippines at least annually at our own cost to oversee activities. Pipeline has a small activity in Melbourne’s Western suburbs to connect and support local women through a variety of activities

Do they share the Gospel?

  • It appears not.
    • Ministry comment: ‘All activities are humanitarian in nature.’

What impact are they having?

  • Nothing found.

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

  • The expenses are not presented to allow this calculation.
    • Ministry comment: ‘All activities in Australia and the Philippines are carried out by volunteers.  Expenses such as volunteers travelling to the Philippines are paid by the volunteers.  A part time co-ordinator in the Philippines is paid a small allowance, but this money does not come from donations to Pipeline.  All money raised by or donated to Pipeline is used to support others in need.’

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • NA – not offered.

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

  • For a straight donation, no choices are shown on the website.
    • Ministry comment: ‘Please contact Pipeline (see link on website) if you would like to direct a donation to a specific activity.’
  • You can also ‘Sponsor a child’s education or
  • Buy an Amazing Gift Card
    • Schooling and School Supplies…
    • Support a Community Worker…’
    • Women’s Health (sic) Clinic’
    • Livestock…
    • Child Feeding Program’
  • ‘Provide ongoing support to a community worker. Please contact us.’

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Pipeline’ is neither a business name nor a trading name.
    • No outcomes reported.
    • The ‘Expenses/Payments’ do not match those in the Financial Report.
  • Financial Report 2016:  Yes – but only because they don’t have to lodge one.
    • Having lodged one voluntarily, there is no requirement for it to comply with the ACNC’s requirements.
    • 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.”
      • There is no audit report.
      • Even without this omission, it is arguable that a financial report that lacks two of the four financial statements required by the accounting profession, deviates markedly from what is required for the other two, and has no directors’ declaration, is not ‘appropriate’.

What financial situation was shown in that Report?

  • Recognising that the financial statements are unaudited, and that the statements are not compliant with the Accounting Standards –
    • PMIrecorded a deficit, a deficit that was 18% of revenue.
    • The AIS 2016 says that almost 100% of the expenses were ‘Grants and donations…for use outside Australia’, but there isn’t enough to tell which organisations received this money.
    • Zero liabilities.
    • The remaining equity is only 1.5 times the last deficit.

What did the auditor say about the last financial statements?

  • NA (see above).

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

  • Not quite – ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

  • Not shown on the website,
  • But from ‘Responsible Persons’ on the ACNC Register:
    • Glenis Brown
    • Thompson Debra (the wrong way around?)
    • Colin Lesueur
    • Denise Prince
    • Roger Vistarini

To whom is PMI accountable?

  • To Missions Interlink[2] via their Associate membership.
  • Also to the Victorian regulator of incorporated associations.
  • And, as an Australian registered charity, to the ACNC.

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of that accountability, see the section Activities in this review.

International Gospel Centre Inc: mini-charity review

Mini charity review of International Gospel Centre Inc (IGC), an Associate member of Missions Link, and an organisation that asks you, online, to donate to it.

Is it responsive to feedback?

  • When sent a draft of this review, they responded immediately, and with openness and humility. The ensuing conversation led to the correction of an error, a rephrasing, the comments you see throughout below, and this general comment:
    • Thank you for the opportunity to respond to your review. Your ministry is very important and we respond in the love of Jesus. Have made comment and/or correction under each applicable point you raise as necessary. Please let me know if there is anything else you require.

Is IGC registered?

  • As a charity, yes.
  • Incorporated as a South Australian incorporated association (A12906).
  • Business names? None
    • Under the legislation (section 54) for this incorporation, IGC, because it doesn’t have any business names, must use its full name, including ‘Inc’ or ‘Incorporated’, on ‘every notice, advertisement, bill of exchange, receipt or other document given, published, drawn or issued by the association[1].
      • Ministry comment: ‘International Gospel Centre Inc. uses our registered and official name to the best of our knowledge. We are ascertaining where this hasn’t occurred in the past and taking steps to ensure it does as we move forward. We’re also looking at a “trading as” name to allow us to use IGC- Compassion LOVE Action as an addition to International Gospel Centre Inc.’
      • It is arguable that, nowadays, this includes at least some of what is published on IGC’s social media pages.
        • Ministry comment: ‘IGC has sent a request to Facebook to change our Facebook name to International Gospel Centre.’
    • It also cannot trade under the names ‘IGC Foundation’ (YouTube)[2], or ‘IGC’ (Facebook)[3].
      • Ministry comment: ‘We are looking at all of our social media to ensure that not only are we removing confusion but ensuring there are no questions in regards to legality.’
  • IGC says, on the ACNC Register, that it operates in all eight states.
    • It does not have the necessary ASIC registration (an ARBN).
      • Ministry comment: ‘We are incorporated under state law, we are on the ASIC register, and do not have offices in any other state except for SA. The use of the word “operate” is ambigious and we will make the necessary change on the ACNC Register.’
    • It has a fundraising licence in South Australia, New South Wales, Victoria and Western Australia. Perhaps it has assessed that one is not required in the other three states that have a licensing regime?[4]
      • Ministry comment: ‘Our understanding is that we do not need a license in the other states and territories as we do not physically operate in these places. If we held an event in any of these places, we would require a license but I note the following: Qld is okay as we are registered through ACNC; Tas covered by SA license; ACT if donations are $15k per year or more; (and) NT is only required if we sell raffle tickets.

What do they do?

  • ‘For more than 26 years, ‘International Gospel Centre’ has been committed to reaching the most destitute and vulnerable children in the Philippines, Uganda and Zambia by impacting their lives with the power of love in action – giving them hope for the future. We do this through comprehensive and effective programs that not only reach each child, but their families and their local and wider communities. Our largest program is Child Sponsorship where, for a small donation each month, sponsors provide children with basic health and education costs.’ [‘Who we are’]
  • But they don’t do this themselves:
    • ‘Our mission partners with ‘IGC Foundation SE Asia’ in Cebu, Philippines, ‘ABC Children’s Aid’ in Uganda and ‘Grace Ministries’ in Zambia.
    • Partnerships?
      • The banner on the home page suggests that the relationship between IGC and the overseas organisations is considerably more than the usual partnership: it says ‘IGC International Gospel Centre Inc.’ ‘IGC Zambia’, ‘Philippines IGC Foundation SE Asia’, and ‘IGC Uganda’.
        • Ministry comment: ‘These partners operate from funds received from our fundraising activities. We are in the process of changing our web site to better reflect the partnership arrangements.’
      • There is no doubt that there is a strong relationship between IGC Foundation SEAsia Inc and IGC, but the IGC website does not make that relationship clear. In most places it presents them as two parts of an IGC whole, even interchangeably. For instance, both IGCs are described under ‘Our Team’.
        • The relationship between IGC Foundation SEAsia Inc, Pro Vision Kids and Christian Frontier Ministries is also not clear.
          • Ministry comment: ‘The relationship will be made clear in our new website and, as required, through our published materials. Agree that it is currently ambigious.’
          • Then there’s The Jesus Fellowship.
            • Ministry comment: ‘This is part of another organisation that works in conjunction with the Field Directors but is separate and should be separate on our website.’
        • There is no mention on the page for Uganda that it what is being talked about is the activities of a separate Ugandan organisation. And with the similar page for Zambia, it is not until half way through that it is apparent that the article was written by the partner (Grace Ministries Mission International).
          • Ministry comment: ‘New website being developed. This will also clearly define our partnership arrangement.’
        • IGC says, in a Note to the accounts, that it ‘ensures that funds are received and expended for designated purposes.’
          • Ministry comment: ‘Our partnership arrangements are very clear in this regard.’

Do they share the Gospel?

  • NA. (Assuming that their partners are not actually ICG entities – see the discussion above – then they just collect money to fund their partners’ programs.)
    • Although IGC’s first ‘Entity Subtype’ on the ACNC Register is one that is consistent with sharing the Gospel, sharing the Gospel is not required by their constitution (under either ‘Purpose’ or ‘Objectives’).
  • The partners: Yes, they do share the Gospel – at least the one in the Philippines does:
    • Ministry comment: ‘We are strengthening the relationship between us and our partners to truly reflect the fact that our foundation is in Jesus Christ. That is, our “business model” exists to enable the sharing of the Gospel. This is a carry over from the past and we will be very clear as we move forward and remove any ambiguity.’

What impact are they having?

  • Nothing found.
    • Ministry comment: ‘This is a very important part of our public engagement and will be incorporated into the website we are developing.’

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

  • Ministry comment: ‘These “costs” are donated “in kind” by a benefactor.
  • If we define ‘direct’ as ‘Overseas Mission Distributions’, then it cost $101K to send $278K (that is, 27%).

Can you get a tax deduction?

  • Yes
    • But how does this fit with the fact that the Gospel is shared by at least one of the partners?
      • Ministry comment: ‘We are currently working through this.

Is their online giving secure?

  • PayPal is used, so yes.

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

  • None

Is their reporting up-to-date?

  • Yes (lodged seven months after their year-end, a week before the deadline).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • IGC – Compassion LOVE Action is neither a business name nor a trading name.
    • No outcomes reported.
    • The figure for ‘Other Income’ does not match that in the Financial Report.
    • Ministry comment: ‘Thank you, we take this on notice.’
  • Financial Report 2016:  Questionable
    • The choice of special purpose financial statements over normal statements, a choice that allows less than full compliance with the Accounting Standards, is, given the size and complexity of the charity, questionable.
      • The directors say that the financial statements ‘do not purport to be general purpose financial statements’, but they do not say what they are.
      • The directors don’t say why they didn’t produce general purpose financial statements.
    • The direct adjustment of equity, that is, not via the Statement of Comprehensive Income, of $45K (1.8 times the deficit), is said to be due to revised accounting policies and ‘other direct adjustments’. There is insufficient information disclosed about these changes. Has the applicable Accounting Standard been followed?
    • The ACNC Act, the legislation under which IGC reports, is not mentioned.
    • There is no disclosure of related parties (an ACNC expectation).
    • How is an office run without any non-current assets (including, for instance, office equipment)?
    • The distinction between direct and indirect income is not explained. Why would donations be direct but legacies – another form of donation – indirect?
    • The explanation for ‘Apostolic Ministry Expenses’, and the associated income, is guarded:
      • ‘Transactions described as Apostolic Ministry income and expenditure are made in various forms and include donations received, remuneration payments and benefits to a significant promoter of IGC. These payments are directly funded by donations in support of the Apostolic work of IGC together with direct ministry income that IGC derives from the Apostolic ministry within the organisation.’
        • There is no mention of any ‘apostolic’ activity on the website.
        • Remuneration should be included under Employee benefits expense.
        • If money is received on behalf of another ministry it should not be included in revenue.
        • Is it the money that is talked about by Cliff and Helen Beard on their site?
    • The name on the largest ‘mission distribution’, Cebu Missionary Foundation (Philippines) does not match the name of the partner elsewhere in the IGC material. (The name is nowhere on the website.)
    • Many of the Notes one would expect to see are missing.
      • Ministry comment:Thank you, we take this on notice.’

What financial situation was shown in that Report?

  • Last year’s surplus of 30% of income was dramatically reversed this year, to a negative 7%.
  • Minimal liabilities – either current or non-current.
  • No non-current assets.
  • Salaries and wages $45K: this is for one part-time employee [AIS 2016].

What did the auditor say about the last financial statements?

  • He said that ‘nothing has come to our attention that causes us to believe that the financial report…does not satisfy the requirements of (the ACNC Act)’. So not an audit, but the lesser assurance from a review[5].

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

  • Yes

Who are the people controlling the organisation?

  • There is an undated photo of the ‘IGC Australia Board Members’ on the website, but no names.
  • There are eleven people in the photo but only five on the ACNC Register:
  • Ministry comment: ‘Our board will be reflected on our new website.’

To whom is IGC accountable?

  • To Missions Interlink[6] via their Associate membership.
  • Also to the South Australian regulator of incorporated associations.
  • And, as an Australian registered charity, to the ACNC.

 

 

  1. The only exception is in the Regulations: For the purposes of section 54 of the Act, a chit or ticket evidencing the receipt by an association of an amount not exceeding $10 is prescribed as a receipt or document to which that section does not apply.
  2. Duplicated by, for instance, Investigator College.
  3. Duplicated by, for instance, a recent consultant of IGC.
  4. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  5. As he says in his report, ‘A review…consists of making enquiries, primarily of persons responsible for financial and accounting matters, and applying analytical and other review procedures. A review is substantially less in scope than an audit…and consequently does not enable us to obtain assurance that we would become aware of all significant matters that might be identified in an audit.’
  6. For one opinion on the strength of that accountability, see the section Activities in this review.

CWCI International: mini-charity review

Mini charity review of CWCI International (CWCI), as an organisation that invites you, on its website, to donate to it. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • They did not respond to the draft that I sent them on 10 February, nor, because of the ABN added to their website, to the amended draft sent on 27 February.

Is CWCI registered?

  • Yes, as a charity. But in a different name, Christian Women Communicating International.
    • The name they are using, CWCI International, is not registered to them.
    • Not to be confused with the charity, CWCI International Aust Inc Halls Gap Committee.
  • Not to be confused with Christian Women Communicating Intl in Aust.

What does CWCI do?

  • ‘The International Board’s primary ministry is to arrange the production of Know Your Bible (KYB) studies and their translation for use worldwide’ (emphasis in original) [http://www.cwci.org.au/about.php].
  • Donations are for ‘the current translation projects’.

Do they share the Gospel?

  • Not their mission.

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 information is available.
    • As a Basic Religious Charity they are even exempt from completing Section E of the Annual Information Statement 2015 (AIS 2015).
    • 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.” So just ask.

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?

  • None

Is their reporting up-to-date?

  • Yes (six months after their year-end, two days before the deadline).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Almost – no outcomes are given.
  • Financial Report 2015: Yes

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • No audit report has been made public.

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

  • Except for their phone number, yes.

Who are the people controlling the organisation?

  • No names on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Margaret Gardner
    • Kate Graham
    • Diana James
    • Lynette Schier
    • Lisa Watson

To whom is CWCI accountable?

NT Christian Schools: mini-charity review

Mini-charity review of NT Christian Schools (NTCS), an organisation that is an Associate member of Missions Interlink.

Are they responsive to feedback?

  • They did not respond to the draft I sent on 24 February.

Is NTCS registered?

  • Yes, as a charity.
  • As a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
  • Fundraising licences: it only operates in the Northern Territory and that state doesn’t have a fundraising licensing regime.

What does NTCS do?

  • While from the name you might think that they are a representative organization for Northern Territory Christian schools, NTCS actually owns and runs five colleges and three schools itself.

Do they share the Gospel?

  • Their Statement of Faith, ‘the central document of this organisation’, says that ‘God wants us to tell people about Jesus and why He died for us’, but the use of ‘Gospel’, ‘Jesus’, and ‘Christ’ on the website suggests that this is too difficult in practice.

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?

  • Insufficient information is published to allow this calculation.

Can you get a tax deduction?

  • Not to NTCS itself, but to its fund Northern Territory Christian Schools Building Fund

Is their online giving secure?

  • NA – they don’t seek donations online.

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

  • NA

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2015 (AIS 2015): Apart from the absence of outcomes, yes.
  • Financial Report 2015: No
    • From Section E of the AIS 2015 we know that NTCS produced the lower standard special purpose financial statements. For an organisation running eight public educational institutions all over the Northern Territory, using principally taxpayers’ money ($23.01 m of it), it is implausible that all the stakeholders, both present and prospective, have the capacity to command the preparation of a financial statements tailored to their needs.
    • Because NTCS’s schools are non-government schools, NTCS was not required to lodge a Financial Report.
    • 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.”  So just ask.

What financial situation was shown in that Report?

  • No report is publicly available.
  • From Section E of the AIS 2015:
    • The had a deficit of 3% of Gross Income.
    • Over 70% of Gross Income is from government grants.
    • Current assets are only 60% of current liabilities.
      • Did the auditor comment on this?
    • Long-term financial structure is sound.

What did the auditor say about the last financial statements?

  • No audit report is available publicly.
    • The last page of the audit report is included in the Annual Report. This shows a ‘clean opinion’.
      • However, the auditor agreed with the directors’ view that special purpose financial statements are appropriate.

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

  • Almost – it is missing some responsible persons.

Who are the people controlling the organisation?

  • Not directly shown on the website.
  • The ACNC Register show only two people, with only one of those matching the above list:
    • Danielle Little
    • Phoebe Van Bentum

To whom is NTCS accountable?

  • To Missions Interlink[1] via its an Associate membership.
  • NTCS is also accountable to the ACNC.
  • And, as a company, to ASIC.

 

 

  1. For one opinion on the strength of that accountability, see the section Activities in this review.

Moore Theological College Council: mini-charity review

Mini charity review of Moore Theological College Council (MTC) as an organisation that invites you, on its website, to donate to it. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is it responsive to feedback?

  • When sent a draft of this review, they replied the same day to say that they did ‘not want to pursue this’.

Is MTC registered?

  • As a charity, yes.
    • There are two other charities with Moore Theological College in their name: Church Property Trust – Moore Theological College Library Ordinances and Moore Theological College – M F Abel Trust – Church Property Trust. What is their relationship to RTC?
    • Note 1(t) in the accounts says that ‘The Council acts as Trustee for Moore Theological College Special Purpose Trust Funds’. This fund does not have an ABN. It is not included in MTC’s accounts.
  • With business names:
    • It uses three names instead of MTC: Moore College, Moore Theological College registered, and Moore. Moore is not a business name.
    • It has four ‘centres’: Centre for Ministry Development, Priscilla&Aquila Centre, Centre for Christian Living, and Centre for Global Mission. All are business names.
      • In the Annual Report 2016, the principal says that they only have three centres, the first three above.
        • Why then is MTC’s membership of Missions Interlink in the name of the fourth, Centre for Global Mission?
    • The ABN record shows only two of these six business names.
      • Plus one that is no longer used, John Chapman Preaching Centre.
  • Incorporation:
    • RTC is ‘a Body Corporate under the Anglican Church of Australia (Bodies Corporate) Act 1938 [Financial Report, page 5].
    • The ABN record says that RTC is an ‘Other Incorporated Entity’. ASIC says that it is unincorporated.
  • TC doesn’t have a fundraising licence in the state in which, per the ACNC Register, it operates. Nor in the other six states that have a licensing regime[1].

What does MTC do?

Do they share the Gospel?

  • No – at least not to show who haven’t heard it.

What impact are they having?

  • Presumably the intended impact is the change brought about in the students. No information found on this.

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

  • The expenses are not classified to allow this calculation.

Can you get a tax deduction?

  • Yes
    • Including the two funds that MTC runs, Moore Theological College Building Fund, and Moore Theological College Library Fund.
      • There is one incidental mention of the first fund, and nothing on the second fund, on the website.

Is their online giving secure?

  • The first page says that giving is secure, but you have fill in your details before you see what that means.

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

  • General work of the College’
  • ‘The new building capital campaign’
    • Note the absence of both the tax-deductible funds (see ‘Can you get…’, above).

Is their reporting up-to-date?

  • Yes (four and a half months after year end).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Not quite:
    • Business names are missing.
    • No outcomes are reported.
  • Financial Report 2015: No
    • It is implausible for an organisation that shows Gross Income of $15.25 m, including $11.81 m from the taxpayer and $2.58 m from donors, 144 employees (AIS 2015), over 500 students, and creditors for $2.26m, to have ‘no users dependent on general purpose financial reports’.
      • This means that MTC can produce financial statements that don’t have to comply with all the Accounting Standards, and implies that all users, both present and prospective, can command the preparation of reports tailored to their needs.
      • For a small organisation with limited resources, a decision such as this might be excusable, but from a major player in the Christian community with the resources of the Anglican Church behind it, is it arrogance rather than ignorance?

What financial situation was shown in that Report?

  • The surplus was a high 21% of Gross Income (AIS 2015).
  • Trade payables increased nearly 10 times to $1.61 m. (There is no explanation.)
  • Although current liabilities were $3.80 m, working capital (current assets less current liabilities) was strongly positive.
  • Long term financial structure is sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he agreed with the directors’ decision to produce the lower disclosure special purpose financial statements.

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

  • No
    • the business names are missing.
    • ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

  • Those listed here.
  • The list under ‘Responsible Persons’ on the ACNC Register has the same, except without J.L. Ramsay:
    • Ken Chapman
    • Anthony Clemens
    • David Cohen
    • Glenn Davies
    • Christopher Edwards
    • William Hurditch
    • Talar Khatchoyan
    • Andrew Killen
    • Kevin Kim
    • Gary Koo
    • Edward Loane
    • Mark Thompson
    • Robert Tong
    • Diane Warren
    • There are 386 directorships recorded for the name ‘Glenn Davies’ and 362 for ‘Robert Tong’. Yes, 386 and 362. These people may have directorships other than charities, so these numbers may be higher. If after eliminating the entries in the Register that don’t belong to MTC’s Glenn Davies and Robert Tong, you are left with their total being more than a handful, something that seems likely at least for the Bishop, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.
      • The same, although to a much lesser extent, applies to ‘David Cohen’ (9), Christopher Edwards (10), and Mark Thompson (9).

To whom is MTC accountable?

  • To Missions Interlink, because it’s an Associate member.
  • To the Synod of the Anglican Diocese of Sydney.
  • MTC is also accountable to the ACNC.

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Global Frontier Missions: mini-charity review

Mini-charity review of Global Frontier Missions (GFM), an organisation that is an Associate member of Missions Interlink and which invites the public, via the website linked from that membership, to donate to it.

Are they responsive to feedback?

  • They have not responded to the draft I sent on 20 February.

Is GFM registered?

  • Yes, as a charity.
  • An association, but not incorporated.
    • This means that GFM cannot enter contracts in its own name.
  • No fundraising licence held in the only state in which it says it operates, its home state[1]

What does GFM do?

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?

  • No financial information is published, so it is not possible to make this calculation.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned.

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

  • 12
    • But not all may be applicable to Australia.

Is their reporting up-to-date?

  • Yes – they only began on 1 July 2016, so none has been required yet.

Does their reporting comply with the regulator’s requirements?

  • Yes – none required yet.

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • NA

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

  • Far from it:
    • No ‘Entity Subtype’
    • P.O. Box for ‘Charity Street Address’
    • ‘Email’, ‘Phone’, and ‘Website’ are blank
    • Only one Responsible Person shown.

Who are the people controlling the organisation?

  • The webpage on Australia does not mention the GFM committee.
  • The constitution requires a minimum of three members, but there’s only one on the ACNC Register:

To whom is GFM accountable?

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of that accountability, see the section Activities in this review.

Vose Seminary: mini-charity review

Mini-charity review of Vose Seminary (VS), as an organisation that invites you, on its website, to donate to it (and is an Associate member of Missions Interlink). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is VS registered?

Is VS responsive to feedback?

  • They have not responded to the draft I sent on 18 February.

What does VS do?

Do they share the Gospel?

  • No – at least not to those who haven’t heard it.

What impact are they having?

  • No information found.
    • A Google search of the website shows that an annual report must be produced, but it’s not on the website.

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

  • No calculation is possible – no financial statements for VS are available.
    • VS is an operating arm of The Baptist Union of Western Australia Incorporated. Its results are therefore included in their results.

Can you get a tax deduction?

  • Donations are sought only for ‘Vose’s ‘Invest in the Future’ Capital Campaign’. There it says that ‘All donations are tax deductible’.
    • Presumably this is referring to the two tax-deductible funds run by The Baptist Union of Western Australia Incorporated, ‘Vose Seminary’ and ‘Vose Seminary Library’.

Is their online giving secure?

  • NA – not offered.

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

  • Only the ‘Invest in the Future’ Capital Campaign’ is offered.

Is their reporting up-to-date?

  • They don’t report separately.

Does their reporting comply with the regulator’s requirements?

  • They don’t report separately.

What financial situation was shown in that Report?

  • There is no information about VS in The Baptist Union…’s reports.

What did the auditor say about the last financial statements?

  • NA

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

  • NA

Who are the people controlling the organisation?

  • Only the staff are shown on the website.
  • Here, from ‘Responsible Persons’ on the ACNC Register, and the people who govern The Baptist Union…, and therefore presumably VS as well:
    • Vanessa Chang
      • Is it this Vanessa Chang?
    • Craig Eccleston
    • Bradley Entwistle
      • Is it this Brad Entwistle?
    • Gregory Holland
    • Karen Siggins
    • Darren South
    • Bruce Watkins
    • Mark Wilson
    • There are 12 directorships recorded for the name ‘Mark Wilson’, nine for ‘Gregory Holland’.  The ACNC Register has only charities, so if, after eliminating the entries in the Register that don’t belong to VS’s Mark Wilson and Gregory Holland, you are left with their total being more than a handful, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.

To whom is VS accountable?

  • VS is an Associate member of Missions Interlink. However, as VS is not an entity without even an ABN, presumably it is The Baptist Union…that should be shown as the member.

Tabor College of Higher Education: mini-charity review

Mini charity review of Tabor College of Higher Education (TC) as an organisation that invites you, on its website, to donate to it. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is it responsive to feedback?

  • They have not responded to the draft I sent on 17 February.

Is TC registered?

  • As a charity, yes.
    • But in a different name: Tabor College Inc.
      • TC does not have the name Tabor College of Higher Education registered as a business name.
  • It appears that TC controls another charity, The Trustee For Tabor College Inc Trust.
    • But TC hasn’t take advantage of the ACNC’s group reporting concessions, meaning that this subsidiary (and any others) must report separately.
  • Other registrations:
    • As a South Australian incorporated association (A6378).
      • Not to be confused with the Western Australian association of the same name.
    • An ARBN, allowing it to operate interstate.
    • TC operates, per the ACNC Register, in South Australia and Western Australia. It doesn’t have a fundraising licence in these two states, or in the other five that have a licensing regime[1].

What does TC do?

  • See the mission here, and the three commitments that the President thinks are reasons for a student to enrol with them.
  • Beside the campus in Adelaide, they have had one in Perth since 2015.

Do they share the Gospel?

  • No – at least not to show who haven’t heard it.

What impact are they having?

  • No information found.
    • No educational outcomes given in the Annual Information Statement 2015 (AIS 2015).

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

  • The expenses are not classified to allow this calculation; for instance, ‘Salaries & Wages are not classified by the function of the employee.

Can you get a tax deduction?

  • Yes
    • Also to a fund that TC runs, The House of Tabor Building Fund Inc.
      • This is not, as the name suggests, an incorporated association.
      • There is no mention of this fund on the website.

Is their online giving secure?

  • Secured by Commonwealth Bank’, so yes.

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

  • None shown online.

Is their reporting up-to-date?

  • Yes (six months after year end, a day late).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • Business names are missing.
    • No outcomes are reported.
    • ‘Other Income’ does not match the figure in the financial statements.
  • Financial Report 2015: No
    • Neither the directors nor the auditor comment on what the poor results and financial position mean for the going concern assumption.
    • Why isn’t their subsidiary included in the results?
    • It is implausible for an organisation that has revenue of $6.43 m, including money from the taxpayer of $1.32 m, campuses in two states, 143 employees (AIS 2015), and hundreds of students, to say that it is reasonable to produce the type of financial statements that don’t have to comply with all the Accounting Standards.
      • Not only that, but then only one of these Standards has been followed, rather than the usual subset of those required for the type of statements they have produced.
    • Balance Sheet
      • There’s an unexplained treatment of borrowing costs.
      • The valuation basis of the land and buildings is not given.
      • ‘Registration and Accreditation’ is included as an asset without explanation.
    • Income Statement
      • A ‘Transfer From Reserves’ is shown as income.
      • There is no ‘Other Comprehensive Income’ section.
      • There’s an unexplained treatment of prior year adjustments.
    • Notes to the Financial Statements
      • Note 1 is missing most of the required Notes.
      • There is no related parties’ disclosure.
    • Statement of Changes in Equity
      • The deficit does not match the amount shown in the Income Statement.
    • The Statement of Cash Flows should be included as a statement, not as a Note.
    • The directors do not say why the think that PBC is not a reporting entity.
    • The audit report is deficient (see below).
    • Neither the directors nor the auditor mention the ACNC Act.
    • The name of the entity is wrong in the directors’ declaration.

What financial situation was shown in that Report?

  • Keeping in mind what is said in the previous section
    • A surplus of less than 1% of revenue was turned into a deficit of 3% of revenue.
    • ‘Salaries & Wages’ (actually ‘employee benefits expense’ I think) were 83% of expenses.
    • For at least the last two years, working capital (current assets less current liabilities) has been negative.
    • Non-current borrowings increased from $1.66 m to $1.91 m.
    • Is the going concern assumption valid?

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he
      • makes no comment on the going concern assumption,
      • agreed with the directors’ decision to produce the lower disclosure special purpose financial statements,
      • excludes the directors’ declaration from the scope of his audit,
      • gives contradictory information on whether he assessed TC’s accounting policies, and
      • has not included an Emphasis of Matter paragraph.

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

  • Almost – the business names are missing.

Who are the people controlling the organisation?

To whom is TC accountable?

  • To Missions Interlink, because it’s an Associate member.
  • TC is also accountable to the ACNC, and to the South Australian associations regulator.

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.