Healthcare Christian Fellowship Oceania Inc.: mini charity review

Mini charity review of Healthcare Christian Fellowship Oceania Inc. (HCFO), an organisation that is exempt from Australian income tax via its membership 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 on 15 August 2017. See their responses below.

Is HCFO registered?

  • As a charity, yes
  • Other registrations:
    • As a Victorian incorporated association (No. A0043417L).
    • Given the low level of donations, I did not check for fundraising licences.
    • Not registered for GST – but it is below the limit where it is required.
  • Missing: The ACNC Register says that HCFO operates in all eight states. It doesn’t have the necessary ARBN registration to do this legally.
    • Ministry comment: HCFO does not have committee structures in States other than Victoria.  However, it has supporters in all the major states who pray, give and occasionally join teams for overseas missions.

What do they do?

  • From the Annual Information Statement (AIS) 2016:
    • At our mission trips in PNG, Vanuatu and Tonga, many committed their lives to follow God and commenced a dynamic walk with God.
    • There’s no website – the one linked from Missions Interlink belongs to the overseas organisation – but from their constitution (clause 2), this is what they are doing when they are on these mission trips:
      • “…train, equip and disciple Christian healthcare workers in subjects such as total patient care, care of the dying and medical ethics.
      • …share the love of Christ to all those interested, in the healthcare field….
      • …promote biblical Christian healthcare
      • …become a prayerful fellowship with trained people implementing Christ’s great commission within the healthcare field.’
  • Ministry comment: HCFO’s activities include:
    • Praying for the ministry of Christian Health Care workers around the world
    • Encouraging and supporting Christian health care workers in Oceania to have a Biblical and holistic approach to their ministry
    • Sending mission teams from within the region to needy areas in Oceania to provide a holistic approach to care for medical patients through clinics, counselling sessions, training and evangelistic Church services in the community.

Do they share the Gospel [1]?

  • From the above results, yes.
  • Probably via the ‘spiritual counselling’ they do.
    • Ministry comment: Mainly through spiritual counselling and also by working with the local pastors and evangelists in outreach meetings to the community and prisons during the “mission trips”.

What impact are they having?

  • See ‘What do they do?’ (above).

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

  • There are no financial statements, but from the AIS 2016, expenses other than ‘Grants and donations made…’ are 19% of the total.
  • This is much larger than the percentage mentioned on the international organisation’s website:
    • Since almost all our staff are volunteers, our overhead costs are limited to a maximum of 5% of our budget.
    • Ministry comment: Administration costs are covered through the registration fees charged for mission trips. Each participant travelling on our mission trip pay for the full cost themselves. Donations and funds raised through family and friends are used for steps to peace with God booklet, bibles, spectacles and similar expenses.

Do they pay their directors?

  • There are no financial statements, and it’s not possible to tell from the limited information disclosed in the AIS 2016. But if they did pay them, it wasn’t much.
    • Ministry comment: No

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA. (Nor is it available on the international organisation’s site.)

Where were your (net) donations sent?

  • The countries listed on the ACNC Register are most likely the destination for the overseas grants (the bulk of the money), but no further information is available.
    • Ministry comment: Majority of the funds are spent on mission trip related costs mentioned above, which include PNG, Vanuatu and Tonga.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Yes
  • Financial Report 2016: NA
    • One isn’t required by the ACNC, and HCFO haven’t lodged one voluntarily.
    • If you want their latest financial report then their membership of Missions Interlink supports your request: they are required to “have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor” [Standards Statement, 4.1].)
      • The ‘Annual Report’ under ‘Charity’s Documents’ on the ACNC Register is just an Income and Expenditure Statement and a Balance Sheet for three years ago.

What was the financial situation shown by that Report?

  • NA
    • The AIS 2016 shows a surplus of 13% of revenue, assets of $50K and only $4K of liabilities.

What did the auditor say about the last financial statements?

  • NA

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

  • Yes

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

  • NA

Who are the people controlling the organisation?

  • No website, so here’s the directors from the ACNC Register.
    • Anna Ariaratnam
    • Mohan Bangah
    • Sean George
    • Chelliah Gnanaharan
    • Padmini Gnanaharan
    • Kathleen Merry
    • Michael Sabapathypillai
    • James Suresh
    • Ajith Thomas
  • They answer to the members.

To whom is HCFO accountable?

  • Because of its income tax exemption, HCFO is accountable to Missions Interlink.
    • For one view on the strength of this accountability, see the section Activities in this review.
  • As a registered charity, HCFO is accountable to the ACNC.
  • And to the Victorian regulator of incorporated associations.

 

 

  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. 

Church Missionary Society Western Australia Inc: mini charity review

Mini charity review of Church Missionary Society Western Australia Inc (CMS-WA), an organisation that seeks donations online[1], and is exempt from Australian income tax via its membership 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 on 21 August 2017. They…did not respond.

Is CMS-WA registered?

  • As a charity, yes
  • Even though CMS-WA is a branch of CMS Australia, it is an organisation in its own right, a Western Australian incorporated association (A0750136M).
  • No business names are held, so CMS-WA should always be using its full name.
  • CMS-WA operates, per the ACNC Register, only in Western Australia. It does not have a fundraising licence there. I can see no reason why it would be exempt.
    • As it does not raise money on its website – at least not in its own name – the question of licences in the other five states that have a licensing regime does not arise.

What do they do?

  • See the third section here.
  • CMS Australia is a ‘ministry organisation’ of the Anglican Church, so presumably that relationship includes the branches like CMS-WA.
  • In the AIS 2016:
    • CMS-WA engages with individuals and churches to partner with them to share the great news that God wants His eternal kingdom to be made up of all cultures without discrimination. Our visits to churches and through our 2 events are opportunities to teach that God’s plan it to partner with us to share this great news. CMS is a tax deductible gift recipient for provision of overseas aid in several of the countries we send missionaries to as well as in some work amongst indigenous folk.
      • Note the switch mid-field from CMS-WA to ‘CMS’ (CMS Australia). CMS-WA is not entitled to receive tax deductible gifts.
  • CMS-WA, per the ACNC Register, does not operate overseas.
    • Clause 14 of the Constitution shows that CMS-WA recruits missionaries for CMS-Australia.

Do they share the Gospel [2]?

  • From their ‘Events’, it appears not.

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?

  • If ‘impact’ is defined as the contribution to ‘head office’, CMS Australia, plus ‘Events Expenses’, then 44% goes to ‘administration’.

Do they pay their directors?

  • It appears not.

Can you get a tax deduction?

  • No
    • The ‘Donate’ button in the footer of its webpages leads to a CMS Australia giving facility. Some giving there attracts a tax deduction.

Is their online giving secure?

  • NA
    • CMS Australia (see above) does not mention security.

Where are your (net) donations sent?

  • The only obvious remittance of money in the expenses is the item ‘Funds remitted to CMS-Aust’. This is $134K, or 52% of expenses.
    • The same amount is incorrectly shown as ‘Grants and donations made for use outside Australia’ in the AIS 2016.

Is their reporting up-to-date?

  • Yes (six months after their year-end, a month earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • The description of activities mixes the activities of CMS Australia with those of CMS-WA.
    • No outcomes are reported.
    • The ‘Type of financial statement’ is incorrect.
    • ‘Other income…’, ‘Employee expenses’, and ‘Grants and donations made…’ do not match the same items in the Income Statement.
  • Financial Report 2016: No
    • Most of the issues with the financial statements last year remain.
    • It appears that two pages have been accidentally omitted, including the all-important Note 1.
    • Even with those pages, the Report would fall far short of the ACNC’s expectations.
      • There is no ‘Responsible persons’ declaration.
      • The auditor does not have the professional registration that is required to do this audit.
      • Two of the four compulsory financial statements are missing.
      • Most of the required Notes are missing.
      • The Income Statement uses a long out-of-date format (and is therefore incorrectly titled and missing a key element).
    • For the same reasons, the Report falls far short of any reasonable interpretation of Mission Interlink’s requirement that CMS-WA ‘have available for its members and supporters a clear and appropriate financial  statement which has been approved by its auditor’ [Standards Statement, 4.1].
    • There is no explanation as to why revenue includes tax-deductible donations when CMS-WA is not entitled to receive tax-deductible donations.
    • The directors believe that a special purpose financial report is acceptable. This choice allows them to make less than a full disclosure about CMS-WA’s finances and operations, and is implicitly a statement that any current or prospective user can command the preparation of a financial report tailored to their needs. Do the directors realise they are saying this?
    • The report does not explain the relationship between CMS-WA and CMS Australia, something that is integral to understanding the accounts.

What was the financial situation shown by that Report?

  • The surplus as a percentage of income increased markedly, from 11% to 27%.
  • A major contributor to this was the fact that much less money was donated (sent to CMS Australia).
  • ‘Staffing expenses’ rose from sharply from 23% of expenses to 31%.
  • With only $25K of liabilities, both short-term and long-term financial structure are sound.

What did the auditor say about the last financial statements?

  • The auditor, Jeffrey T. Byerley, CPA, has again issued a qualified opinion.
    • Read here to see what this means compared to a ‘clean’ opinion.
    • He says that CMS-WA ‘has determined that it is impracticable to establish control over the collection of gifts and donations prior to entry into its financial records’. So, for 92% of the revenue, CMS-WA cannot be sure that what is included in revenue in the financial statements is all that was given by donors.
    • Why is it not possible for CMS-WA to implement the necessary internal controls? Four out of the other five CMS Australia branches can do it, including the other one that is audited by this auditor.
  • With this size gap in the audit procedures, and the deficiencies described under ‘Financial Report 2016’ (see above), CMS-WA got off lightly – an adverse opinion would seem to be more appropriate.
  • Because he is still not a registered company auditor, the audit has again been done by someone who is not qualified to do it[3].
  • Apart from allowing the accounting choices made by the directors, he has also omitted the obligatory ‘Emphasis of Matter’ paragraph.

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

  • No
    • The selection of a ‘Entity Subtype’ has been overdue since 30 June 2015.
      • ‘Advancing religion’ would seem to be the right selection according to the constitution:
        • The objects of the Branch are to carry out the principles and objects of CMS-A [The Church Missionary Society – Australia Limited] within the State of Western Australia, namely to work for the coming of God’s Kingdom through the proclamation of the Gospel of Christ throughout the world in fellowship with local churches…
    • By far the largest revenue item is ‘General missionary support’. When, then, is ‘Operates in (Countries) blank?
    • ‘Date Established’ is blank.

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

  • NA
    • If you use the ‘Give’ button in the footer of their webpages, CMS Australia has the following choices:
      • General Missionary Support’
      • ‘General Tax Deductible Gift’
      • ‘A particular worker’
      • ‘Other – Choose an option’
        • These include two with CMS-WA in the title:
          • CMS WA Lasting Hope Appeal 2017’
          • ‘CMS WA Membership Contribution’

Who are the people controlling the organisation?

To whom is CMS-WA accountable?

  • Nothing claimed on the website.
  • Because of its income tax exemption, CMS-WA is accountable to Missions Interlink.
    • For one view on the strength of this accountability, see the section Activities in this review.
  • As a registered charity, CMS-WA is accountable to the ACNC.
  • And to the Western Australia regulator of incorporated associations.

 

 

  1. CMS-WA does not have its own website, just a few pages on the CMS Australia site. The ‘Donate’ button in the footer of its webpages leads therefore to a CMS Australia giving facility.
  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. 
  3. Because Western Australian incorporated associations don’t need to submit a financial report to the regulator, the ACNC’s concession to incorporated associations doesn’t apply.

Cosmos Healthcare Incorporated: mini charity review

Mini charity review of Cosmos Healthcare Inc (CH) an organisation that seeks donations online, and is exempt from Australian income tax via its membership 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?

  • I sent them a draft of this review on 21 August 2017. They…did not respond.

Is CH registered?

  • As a charity, yes.
  • CH is a WA incorporated association (No. A1010684A).
  • They trade under the name Cosmos Healthcare, a name that is not registered.
  • CH operates, per the ACNC Register, only in Western Australia. It has a fundraising licence there.
    • Whether it needs one in the other five states that have a licensing regime depends on whether those states think that inviting donations via the internet is ‘fundraising’.

What do they do?

  • They are, in their words, ‘an intercontinental healthcare organisation’. Read more here.
    • They operate, per the ACNC Register, only in Zimbabwe.
  • There’s a good description of what they did in 2016 in the Annual Information Statement (AIS) 2016:
    • Some of Cosmos Healthcare’s purposes are to provide access for people in developing nations to quality health care, health education and water initiatives. In 2016 we assisted a trusted partner organisation in Zimbabwe to deliver cost effective, well managed mobile health services to reach eight communities on a regular basis with clinical care and health education. Cosmos Healthcare also assisted their partners to deliver a water project in Zimbabwe, helping a community of 1200 people access reliable water sources through rain water harvesting and well construction. Cosmos Healthcare sent two primary health teams to Zimbabwe in 2016, consisting of volunteer doctors, nurses, physiotherapists and helpers to work with our partners to encourage, train and deliver health services to many rural communities around Bulawayo, Zimbabwe.

Do they share the Gospel [1]?

  • No
    • Which fits the absence of (a) ‘Advancing religion’ as one of the four ‘entity subtypes’ that CH have listed on the ACNC Register, and (b) Christianity in the description of its objects in the constitution.
    • But if the plan to implement Community Health Evangelism (CHE) comes to pass, sharing the Gospel will be integrated in their work.
      • How will this fit with the fact that the government allows their donors a tax deduction?

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 classified to allow this calculation.
    • For instance, outside ‘Donations’, what portion, if any, of ‘Employment’, ‘Volunteer expenses’, and ‘Team expenses’ were direct to healthcare delivery in Zimbabwe?

Do they pay their directors?

  • It is not possible to tell from the information available.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • Security is not mentioned on the CH giving page, and after that page redirects to GiveNow, neither do their first two pages.

Where were the (net) donations sent?

  • There is no information available.

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

  • ‘Extended Care’
    • The names of 14 people.
  • ‘Medicine Supply Campaign’
  • ‘General Donations’

Is their reporting up-to-date?

  • Yes (seven months after year end, on the last day allowed).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported
  • Financial Report 2016: NA
    • As a ‘Small’ charity, CH doesn’t have to submit a Financial Report.
    • Because it has submitted one voluntarily, the Report doesn’t have to comply with the ACNC’s requirements.
    • But, as a member of Missions Interlink, it is required to ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor’ [Standards Statement, 4.1].
    • The Financial Report would most likely be passed by both the ACNC and Missions Interlink, but against professional standards[2], there’s a few things that can be questioned, all of which continue from last year:
      • The directors effectively say that anybody interested in CH can ask for a financial report tailored to their needs, thereby absolving CH from fully complying with the Accounting Standards.
      • The required reference to the ACNC Act, in the Statement by the Committee of Management, is missing.
      • The Statement of Profit or Loss and other Comprehensive Income is missing the ‘other Comprehensive Income’ section.
      • The expenses are a mixed classification.
      • Some Notes are missing.
      • Fundraising and administration expenses are not disclosed.

What financial situation was shown in that Report?

  • Despite a 25% reduction in ‘Employment’ expense, a large rise in (the unexplained) ‘Team expenses’ turned a ‘profit’ of 3% of revenue into a loss of 1%.
  • Relatively low liabilities (all current) means that both short- and long-term financial structure are sound.

What did the auditor say about the last financial statements?

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

  • Yes
    • Both the website and Facebook have a different phone number: (08) 6168 1670.
    • Their trading name is missing, but trading names are largely irrelevant now.

Who are the people controlling the organisation?

  • Those listed here on the website.
  • Which is Darryn Rennie and Denise Nichols more than the ACNC Register (under ‘Responsible Persons’) shows:

To whom is CH accountable?

  • Not mentioned on the website, but they are a member of Missions Interlink.
    • For one opinion of the strength of that accountability, see the section Activities in this review.
  • Also accountable to the ACNC.
  • And to the Western Australian regulator of associations.

 

 

  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. 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.

Emmanuel Relief & Rehabilitation International: mini charity review

Mini charity review of Emmanuel Relief & Rehabilitation International (ERR) an organisation that is exempt from Australian income tax via its membership 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?

  • I sent them a draft of this review on 19 August 2017. They…did not reply.

Is ERR registered?

  • As a charity, yes.
  • ERR is an unincorporated association.
    • It was originally an incorporated association but was deregistered in 2006.
    • Although it’s not taken advantage of it, ERR is an unincorporated body with the ‘Entity Subtype’ ‘Advancing Religion’, so is likely to qualify as a Basic Religious Charity.
    • It has the name Emmanuel International registered as a business name.
      • Its ABN record is therefore incorrect.
  • ERR operates, per the ACNC Register, only in Western Australia. It doesn’t have a fundraising licence there. It needs one if it’s donations come from the public.
  • Part of the ‘EI Network’.

What do they do?

  • In the Annual Information Statement (AIS) 2016 – there is no website – they say very little and the same as last year:
    • distributing (sic) funds to community development projects, raising awareness in Australia by regular meetings, praying for the needy.
  • They operate overseas, per the ACNC Register, in six countries.

Do they share the Gospel [1]?

  • No

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?

  • ‘Grants and donations made…’ were almost 100% of the expenses.

Do they pay their directors?

  • We can’t tell from the information available.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

Where were the (net) donations sent?

  • The grants ‘for use outside Australia’ presumably went to the six countries shown on the ACNC Register. The destination within the countries, and the destination for the grants ‘for use within Australia’, are not disclosed.

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

  • There is no information available on this.

Is their reporting up-to-date?

  • Yes (seven months after year end, five days before the (extended) deadline).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite
    • ‘Other names…’: One name missing, one incorrect.
    • No outcomes reported.
  • Financial Report 2016: NA
    • As a ‘Small’ charity, ERR doesn’t have to submit a Financial Report.
    • Although ERR is a member of Missions Interlink, and one of their requirements is that members ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor’ [Standards Statement, 4.1], they did not choose to lodge one with the ACNC voluntarily.
    • An audit is required by the constitution.

What financial situation was shown in that Report?

  • No Report (see above), but from the AIS 2016:
  • Unlike last year, when it was 100% of income, donations this year were only 71% of income.
  • No ‘Employee expenses/payments’.
  • ERR reported that its accounting method was ‘Cash’, a method that doesn’t generate assets and liabilities (other than cash in the bank). These therefore came from outside the double entry system.
  • Almost 100% of the payments were for ‘Grants and donations…’; $86K went overseas.

What did the auditor say about the last financial statements?

  • No audit report is published.
    • One is required by both the constitution and Missions Interlink.

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

  • Yes
    • ‘No’ for ‘Basic Religious Charity’ may be incorrect.
    • ‘Email’, ‘website’ and ‘phone’ are blank, but are not compulsory.
      • That ERR has no website is confirmed by the listing of ‘National Affiliates’ on Emmanuel International’s site.
      • From there we also get a different email address: australia@e-i.org/. And the phone number: (08) 9386 8488.
    • One name is missing, and one incomplete, under ‘Other Name(s)’.

Who are the people controlling the organisation?

  • As shown on the ACNC Register (under ‘Responsible Persons’):
    • Heather Ellis
    • Babu Simon
    • Mary Roskams
    • Allison Chapple
      • Is Allison this one?

To whom is ERR accountable?

  • They are a member of Missions Interlink.
    • For one opinion of the strength of that accountability, see the section Activities in this review.
  • Also accountable to the ACNC.

 

 

  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. 

MMM International Alliance Incorporated.: mini charity review

Mini charity review of MMM International Alliance Incorporated (MMMI), an organisation that seeks donations online, and is exempt from Australian income tax via its membership 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 on 16 August 2017. They…did not respond.

Is MMMI registered?

  • As a charity, yes.
  • MMMI is a Victorian incorporated association (No. A0053789S).
    • To the extent that it is not always using its full name (for instance, on its website), MMMI appears to be in contravention of its enabling legislation (section 23, Associations Incorporation Reform Act 2012).
  • MMMI operates, per the ACNC Register, in all states except the Australian Capital Territory.
    • I could find no obvious reason for the inclusion of other than Victoria in this list.
    • If it is carrying on business outside Victoria, it does not have the necessary registration (as a registrable Australian body).
    • It doesn’t have any fundraising licences.
      • It doesn’t appear to be fundraising in Victoria, so, apart from exemptions, whether it needs a licence depends on whether the authorities think that MMMI, by calling for donations publicly, is ‘fundraising’ in their territory.

What do they do?

  • In the AIS 2016:
    • The MMM international office supported MMM offices in Australia, New Zealand, Thailand, Hong Kong, Zambia and South Africa to achieve their goals of providing vocational training and hands on practical work project teams to build, renovate or maintain facilities within their region and other countries as requested.
      • This is identical to what’s in the AIS 2015.
      • The website does include Thailand in the list of offices.
      • China and Fiji are also missing compared to the list on the ACNC Register.
  • The purposes in the constitution, surprisingly, do not mention anything about being an organisation that supports national MMM organisations.
    • This approach is continued in the MMI website, where there is little information about the international office’s activities but much on what MMM organisations do.
  • The purposes say that MMMI does not only help Christian organisations, but also those involved in poverty relief. Is this a drafting error?
  • I could not find a report on the International Director’s activities equivalent to the one about 2012 that is lodged under Charity’s Documents on the ACNC Register.

Do they share the Gospel [1]?

  • No

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 classified to allow this calculation.

Do they pay their directors?

  • It appears not.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

Where are your (net) donations sent?

  • There is no indication that the few donations that were received were sent anywhere.

Is their reporting up-to-date?

  • Yes (four and a half months after their year-end, two months earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Except for the absence of outcomes, yes.
  • Financial Report 2016: NA
    • Although not required to submit a financial report to the ACNC (because of its size), MMMI has submitted one anyway.  Because it was a voluntary submission, the Report does not need to comply with the ACNC’s requirements.
    • But MMMI, as a member of Missions Interlink, is required to ‘have available for its members and supporters a clear and appropriate financial  statement which has been approved by its auditor’ [Standards Statement, 4.1].
    • If ‘appropriate’ has any reference at all to what professional accountants do (at least should do), then this Financial Report falls well short of the Missions Interlink requirement:
      • It is missing:
        • Two of the four mandatory financial statements.
        • A responsible persons’ declaration.
        • Notes on the financial statements.
      • The Profit & Loss uses an outdated format, one that has separate profitability calculations for ‘operating’ and ‘non-operating’ items, and that omits ‘Other comprehensive income’.
      • The inclusion of a balance sheet, without explanation, is not consistent with the cash basis of accounting.
        • ‘Bank’ has not been included in Current Assets.
      • There is no mention of MMM International Development Fund.
    • There is no audit report. (Were the statements even audited?)

What was the financial situation shown by that Report?

  • They made a loss equal to 14% of revenue. Up from 8% last year.
  • After adjusting for the incorrect calculation of Current Assets, both short-term and long term financial structure are sound.
  • MMMI is run totally by volunteers.
  • It reported (AIS 2016) that its accounting method was ‘Cash’, a method that doesn’t generate liabilities; therefore, they had to record these outside the double entry system.

What did the auditor say about the last financial statements?

  • NA.
    • Their membership of Missions Interlink (see above) means they should have one though.

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

  • Yes
    • MMM International Alliance is not a registered business name.
    • The website address is still incorrect: ‘net’, nor ‘org’.

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

  • None

Who are the people controlling the organisation?

  • There is no mention of the board on the website.
  • Here they are from the ACNC Register (under ‘Responsible Persons’):

To whom is MMMI accountable?

  • Nothing claimed on the website.
  • Because of its income tax exemption, MMMI is accountable to Missions Interlink.
    • For one view on the strength of this accountability, see the section Activities in this review.
  • As a registered charity, MMMI is accountable to the ACNC.
  • And to the Victorian regulator of incorporated associations.

 

 

  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. 

People International Australia Inc: mini charity review

Mini charity review of People International Australia Inc (PIA), as an organisation that seeks donations online, and is exempt from Australian income tax via its membership 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 on 16 August 2017. They…did not respond.

Is PIA registered?

  • As a charity, yes
  • Other registrations:
    • From 5 February 2016, a NSW incorporated association (INC1501785). (Previously an unincorporated association.)
    • The Australian Business Register was updated for the incorporation on 22 December 2016.
    • The ACNC Register has yet to catch up with the name change.
    • PIA operates, per the ACNC Register, in New South Wales and Victoria. Their office is in NSW, and they have a representative in Victoria (‘Stuart’).
      • If it is carrying on business in Victoria, it does not have the necessary registration (an ARBN).
      • It has a fundraising licence in NSW (expiring 25 August 2017), but not Victoria.
        • It calls for donations on the website. Whether this means it should register for fundraising in one or more of the other five states that have a licensing regime, depends on whether those states interpret this call as ‘fundraising’.

What do they do?

  • The Annual Information Statement (AIS) 2016 says they
    • Raised funds to support gospel work in Australia and overseas.
    • Last year they raised $164K and sent $27K. $120K went on the two full-time employees.
  • ‘About Us’ on the website is about the international organisation.

Do they share the Gospel [1]?

  • Although the first primary objective in the constitution supports it – ‘To take Christ’s love to the people of Central Asia primarily, by establishing and enabling His church, as in the International Covenant of PI’ – PIA don’t do this themselves.

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?

  • There are no financial statements, but from the Annual Information Statement (AIS) 2016, expenses other than ‘Grants and donations made…’, that is, expenses on ‘administration’, are 84% of the total.

Do they pay their directors?

  • There are no financial statements, and it’s not possible to tell from the limited information disclosed in the AIS 2016. But if they did pay them, it wasn’t much.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

Where were your (net) donations sent?

  • People International globally is a mission to the twelve countries of Central Asia, but PIA is only involved, per the ACNC Register, in one country, Pakistan.
  • We are not told to whom donations are sent in Pakistan.

Is their reporting up-to-date?

  • Yes (four months after their year-end, three months earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Yes
  • Financial Report 2016: NA
    • As a ‘Small’ charity, PIA doesn’t have to submit a Financial Report.
    • And it chose not to submit one voluntarily.
    • As a Victorian incorporated association, at least financial statements should have been prepared though:
      • As soon as practical after the end of your incorporated association’s financial year, the committee must ensure that financial statements are prepared.
      • And they ‘must give a true and fair view of its financial performance and position during and at the end of the year.
    • As a member of Missions Interlink, PIA is not only required to prepare financial statements, but it must have them audited:
      • have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor’ [Standards Statement, 4.1].

What was the financial situation shown by that Report?

  • NA
  • But from the AIS 2016:
    • 95% of ‘Revenue/receipts’ was from ‘Donations and bequests’, down from 100% last year.
    • ‘Employee expenses/payments’ have risen from 29% of expenses to 70%.
    • PIA reported that its accounting method was ‘Cash’, a method that doesn’t generate liabilities; therefore, they had to record these outside the double entry system.

What did the auditor say about the last financial statements?

  • NA.
    • Their membership of Missions Interlink (see above) means they should have one though.

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

  • Yes

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

  • If you know their name, you can give to a specific person.

Who are the people controlling the organisation?

  • There is no mention of the board on the website.
  • From ACNC Register (under ‘Responsible Persons’):
    • Darryl Anderson
    • Rachel Driessen
    • Stephen Ellis
    • Moussa Ghazal
    • David Lewis
      • There are 13 directorships recorded for the name ‘David Lewis’.  And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  Therefore, if after eliminating the charities for which David is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.

To whom is PIA accountable?

  • Because of its income tax exemption, PIA is accountable to Missions Interlink.
    • For one view on the strength of this accountability, see the section Activities in this review.
  • As a registered charity, PIA is accountable to the ACNC.
  • And to the New South Wales regulator of incorporated associations.

 

 

 

  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. 

International China Concern (Australia) Ltd: mini charity review

Mini charity review of International China Concern (Australia) Ltd (ICC) as 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 on 14 August. They replied promptly, and the ensuing conversation resulted in the ICC comments inserted throughout the review.

Is ICC registered?

  • As a charity, yes
  • Other registrations:
    • As a public company, a company limited by guarantee.
      • ICC’s constitution does not require all payments to directors to be approved by the Board, so ICC is not permitted to omit ‘Ltd’ when using its legal name.
    • Licensed to fundraise in all the states that have a fundraising regime except Victoria. Exempt there?

What do they do?

  • ICC is a fundraiser for International China Concern overseas.
    • This includes the Walk the Wall in Australia event.
  • From the AIS 2016:
    • Fundraising to assist in providing medical, therapy and education services for disabled and abandoned children in 3 orphanages in China. We help provide nutrition and living accommodation to over 350 children and assist in training in life skills.
  • ICC has no website, and the page for Australia on the international site doesn’t say what they do.
    • Ministry comment: Stakeholders will find International China Concern Australia Limited referenced in the main website (www. chinaconcern.org), however I will get the website changed to International China Concern Australia Limited to make this clearer to people searching online.

Do they share the Gospel [1]?

  • No, ICC itself doesn’t. But hopefully those working in the orphanages are faithful to the first of ICC’s ‘Core Values’, ‘Evangelism’:
    • In the birthing of ICC [the international organisation], GOD did not create an orphanage work with a secondary evangelistic purpose. HE created an evangelistic mission whose primary people group are the poor and needy, disabled and orphaned. We seek to take advantage of every Spirit-led opportunity to share with those who do not yet know Christ as their Saviour.
    • ICC has not nominated ‘Advancing Religion’ as an ‘Entity Subtype’ on the ACNC Register.

What impact are they having?

  • Nothing found.
    • International China Concern has an Annual Summary 2016, which is ‘a collection of impact reports and stories’, but it wouldn’t download for me.
      • Ministry comment: I have had this investigated we were able to replicate this issue with a particular version of EDGE (not all versions). It works fine with Chrome and Mozilla. 

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

  • Based on the financial statements, 92%. Donations made account for only 8% of expenses (down from 17% last year).
    • The AIS 2015 says that they sent 41% overseas (down from 47% last year), but that includes, without explanation, $321K ‘Administration costs’.

Do they pay their directors?

  • Although there is no explicit prohibition in the Constitution, paragraphs 8 and 43 strongly imply that it is not permitted.
    • Ministry comment: International China Concern Australia Ltd do not pay directors any salary or remuneration.  The directors may claim for some reimbursable expenses that are directly related to doing their role as directors (e.g fundraising and promotion amongst other things).
  • The Statement of Profit or Loss and Other Comprehensive Income doesn’t show any directors’ fees.
    • Ministry comment: No Directors fees are paid.

Can you get a tax deduction?

  • No, not to ICC.
    • But at the bottom of the ‘Donate’ page they say that
      • ‘International China Concern is proud to be a partner for Project J282 with Global Development Group (ABN 57 102 400 993). Australian tax deductible (sic) receipts for gifts over $2 with a preference for this project will be issued by GDG. As per ATO guidelines, we advise that if excess funds are received they may be applied to other approved project activities. For more info visit www.gdg.org.au.’
      • However, not only is there no description of this program, but it is not one of the donation options.
      • GDG is not a Christian organisation, and there is an Australian government tax concession involved, so presumably International China Concern must compromise on its ‘Evangelism’ value (see above) in this work.
      • The proportion of International China Concern’s work is with GDP is not disclosed.

Is their online giving secure?

  • Security is not mentioned.
    • Ministry comment: Noted; An area that can be improved by ICC.

Where were your (net) donations sent?

  • Apparently, from the AIS 2016, they were all sent overseas. But to whom is not disclosed.
    • Ministry comment: All funds (apart from China Team Travel/ Accommodation Funds) sent overseas were sent either directly or indirectly to International China Concern’s 3 orphanage projects in PRC; As per the website there are 2 in Hunan Province and one in Henan Province.  The China Team Travel Funds were sent to the ICC China Teams area to purchase accommodation and travel for participants in short-term China Teams. The reference to indirectly sending funds relates to where special equipment such as tailored wheelchairs may have been purchased in Hong Kong  (for example) and the equipment then taken into ICC’s projects.

Is their reporting up-to-date?

  • Yes (four months after their year-end, two 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 thirteen months ago.
      • Ministry comment: The year ending 30/06/2017 financials will be available prior to the 31/10/17, as required by Australian legislation, once the audit process has been completed. These will be lodged on the ACNC website after the board has approved them at the AGM to be held in October 17.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite:
    • The amount for ‘Grants and donations made…’ is significantly more than the amount for ‘Donations’ in the financial statements. By deduction, the difference is ‘Administration costs’. There is no explanation in the financial statements for classifying these costs as donations.
      • Ministry comment: In International China Concern Australia, there are several Australian residents and taxpayers who are engaged by ICC to be responsible for an sphere of responsibility greater than just Australia. Examples are the Chief Operating Officer, The Chief Financial Officer etc.  The practice is that other sister ICC organisations (such as ICC Hong Kong and ICC Canada) reimburse an allocated portion of their costs (including salaries) to offset  the non- Australian costs incurred, so that ICC Australia Ltd only incurs directly their own (user pays cost).
    • No outcomes are given.
      • Ministry comment: GDG regularly audit the ICC  China projects as an arm’s length organisation, to ensure outcomes are being achieved. Additionally ICC do internal audits against pre-defined ‘end-statements’ and rate progress on a regular basis.  These are reported on within the organisation.  ICC could probably do more with external reporting of achieved outcomes.  Some of the outcomes are reported on in facebook and in ICC stories in the regular newsletter which is readily available.
  • Financial Report 2016: Questionable:
    • A major item of revenue (42% of the total) is not a standard revenue item, yet is unexplained.
      • Ministry comment: ICC will aim to add an additional note in the 2017 reporting to make this more understandable.
    • The second largest expense, ‘Administration costs’ seems (from the AIS 2016) to be treated as donations, yet this treatment is not explained.
    • The ACNC is still not mentioned by either the directors or the auditor.
      • Ministry comment: ICC will address this aspect in 2017.
    • The form of the Statement of Changes in Equity does not match the information in the Statement of Profit or Loss and Other Comprehensive Income.

What was the financial situation shown by that Report?

  • 42% of the revenue came from the unexplained ‘Administrative reimbursement’.
    • Ministry comment: Refer notes above.
  • Last year’s very small deficit was turned into a positive 3% of revenue.
    • Ministry comment: Agreed.  Unless a NFP is surplus building, one would expect a faith based organisation to run at either a very small suprplus or very small deficit so that the best possible outcome is achieved while being sustainable.
  • 41% of donations went to paying the one full-time, seven part-time and one casual employee.
    • Of the $393K ‘Payroll and on costs’, it appears that $147K went to the (whatever the leader is called).
      • Ministry comment: ICC believes it pays salaries commensurate with that of the Australian mid-range Charity sector (not big business) .. and a lot of additional volunteer hours are also contributed by role incumbents.
  • Even though ICC is only a fundraiser, 5% of its expenses was incurred on travel.
    • Ministry comment: Agreed, Refer to note regarding staff employed by ICC Australia doing additional duties internationally and being reimbursed from other offices.     Travel was also incurred with ICC’s China based director of Projects doing a promotional / Fundraising speaking tour of ICC Australia’s major cities. In 2016, this initiative raised AUD64,000 after expenses, so ICC considers such initiatives to be worthwhile despite incurring some travel costs.
  • The working capital position – the excess of current (short-term) assets over current (short-term) liabilities – is now healthier.
    • Ministry comment: Agreed, however refer to dot point 2.
  • And the equity (that is, liabilities exceed assets), is no longer negative.
    • Ministry comment: Given that ICC has regular recurring income, a small deficit at one point in time (like year-end) is not considered by ICC to be of significance.

What did the auditor say about the last financial statements?

  • The auditor, Neil S Harding, of Harding Martin, gave a ‘clean’ opinion.
    • To take the right amount of comfort for this finding, please read here and here.
    • Also see ‘Financial Report 2016’, above.

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

  • Yes
    • The website is for the overseas organisation, not ICC.

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

  • The donation page initially suggests that all donations go to ‘the general fund’ or ‘Where most needed’. However, further down you are given an opportunity to select from 16 ‘Donor designations’ (including ‘Where Most Needed’).
    • Ministry comment: ICC Australia Ltd tracks donations made against designation and aims to send the funds donated to the respective designation so that the donor wishes are congruent with International China Concern Australia Ltd actions.  Some donors are happy that their donations go to a ‘Where most needed’ which is the largest need while some have a specific reason for donating to a medical or wheelchair or therapy need as examples.

Who are the people controlling the organisation?

  • The names on the Australian page of the website match the ‘responsible persons’ on the ACNC Register:
  • The board is three larger than allowed by the constitution.
    • Ministry comment: (R)ecently ICC Australia Ltd has passed a new constitution based on the template provided by the ACNC (about to be registered with the ACNC) which permits 9 persons to be appointed to the board.
  • David Gotts, the founder of International China Concern, was eligible to attend five board meetings during the year, but attended none.
    • Ministry comment: True, but David resigned from the board in  2016, due to personal family circumstances.
  • There are only eight members of the company, so the accountability of the board is limited.
    • Ministry comment: With the change in constitution, the number of members will increase overtime, providing greater accountability for the directors of ICC Australia Limited.

To whom is ICC accountable?

  • Apart from the ACNC, it is a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  •  As a registered charity, ICC is accountable to the ACNC.

 

 

 

  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. 

Gospel for Asia (Australia) Inc.: mini charity review

Mini charity review of Gospel for Asia (Australia) Inc. (GFAA) as an organisation that seeks donations online, and that is exempt from Australian income tax via its membership 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 GFAA responsive to feedback?

  • I sent a draft of this review to them on 10 August 2017.  They….did not reply.

Is it registered?

  • As a charity, yes.
  • GFAA is a Queensland incorporated association (QLD IA33675).
  • It claims, via the ACNC Register, to operate in all states of Australia.
    • It has, since 15 February 2016, the necessary ARBN registration (609 736 343) to operate outside Queensland.
    • It has a fundraising licence in four of the six states that require one. Missing South Australia and Western Australia.
  • It is registered for GST.
  • It has only two of the usual three tax concessions, missing the FBT Rebate. This means that fringe benefits paid to its employees are not exempt from fringe benefits tax.
  • It has, since 17 May 2016, the registration to allow it to use the name Gospel for Asia.

What does GFAA do?

  • GFAA is the ‘Australia office’ of Gospel for Asia, Inc in the US[1].
  • Its Annual Information Statement (AIS) 2016 (The ‘Description of charity’s activities and outcomes’) says that ‘The various ministries support impoverished families through assistance with education, health and practical gifts, while sharing the love of Christ to the under-privileged in Asia.’ However, this is not what GFAA does, but what GFAA believes is done with the money it collects from Australians. For GFAA, at least from the evidence of the website and the Financial Report 2016 (see below), does not itself work overseas, but merely raises money and sends it to an organisation they call ‘GFA India’.
  • The cover page of their new (28.10.2016) constitution confirms that they are a link between the ‘Christians of Australia’ and ‘the people of the Asian and Indian sub-continents’[2], not themselves a provider of services.
  • The ‘Major Ministry Areas’ of Gospel for Asia overseas are:
    • National Missionaries’
    • GFA’s Bridge of Hope’
    • Clean Water’
    • ‘Widows/Abandoned Children’
    • ‘Bibles/Gospel Lit.’
    • ‘Church Buildings’
    • ‘Jesus Wells’
    • ‘Compassion Services’
    • ‘Radio in Asia’
    • ‘Bible Colleges’
    • ‘Flood Relief’
    • ‘Children’s Ministries’
    • This list matches neither the donations options (see below), the categories for the money sent overseas (see above), or line items of revenue disclosed in the Financial Report (see below).

Do they share the Gospel [3]?

  • No. They collect donations for an organisation in India.
  • Even if we accept their claim that they do charitable works overseas, their constitution does not support a claim that they share the Gospel:
    • The charity shall have as its pre-eminent purpose and objects a benevolent ministry of charity to those who are deprived or distressed in the Indian and Asian subcontinents [paragraph 2].
  • Is the money they send to ‘GFA India’ used to share the Gospel? GFAA says in the Notes to the accounts (Note 3) that the money went to
    • Compassion Services $84K
    • ‘Education’ $257K
    • ‘Emergency Relief’ $56K
    • ‘Empower the Poor’ $431K
    • ‘Missions, Tools & Support’ $1.09 m
    • ‘Gifts and Donations’ less than 1K

So, to the extent that you donated to an option (see below) that was combined into the ‘Missions, Tools & Support’ category, then it is reasonable to think that you helped share the Gospel.

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?

  • They claim that ‘100% of what you give will go to help those in need’. If this were the case then ‘administration’ would be zero. However, it is not: everything other than ‘Donations’ – their name for the money sent overseas – comprises 13% of expenses.
    • It appears that this is just careless wording. For under this claim there is a link, ‘How is that possible?’:

  • There is no explanation on the ‘Where Most Needed’ donation option that some or all your donation might not get to the ‘field’, that is to the people overseas that you want to help; if fact, quite the opposite is the case:

  • With ‘Home Office fundraising program’ revenue less than $1K, this leaves a large shortfall to be taken from the $212K received for ‘Where Most Needed’.
    • What then is the program revenue item ‘Home Team Support’?

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned.

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

  • When you donate to a charity, and you can designate how you want that donation used, the money should be used that way by the charity. Their membership of Missions Interlink requires them to make sure that this happens. But does it?
  • Money in
    • The options available to you when giving depend on which link you use.
      • These are the options under ‘Donate/Ways to Give’ in the main menu:
        • ‘Tools for Missionaries’
        • ‘Major Ministries’
        • ‘Empower the Poor’
        • ‘From the Stable’
        • ‘Compassion Services’
        • ‘Women’
        • ‘Where Most Needed’
        • ‘Home Team’
        • ‘Manage Existing Sponsorship’
        • ‘Christmas Catalogue’
      • These are the options under the ‘Donate’ button on the home page:
        • ‘Share the love of Christ through your donation’
        • Browse for specific items or areas of ministry’
          • ‘Donate Directly to Where it’s Most Needed’
        • ‘Six Popular Items’
          • ‘Jesus Wells’
          • ‘Widows and Abandoned Children’
          • ‘Unsponsored Children’
          • ‘Hope for Suffering Women’
          • ‘Leprosy Ministry’
          • ‘Bibles’
          • ‘Church Building’
          • That’s seven.
      • And on the left-hand side of the same page, ‘Sponsorship Options’:
        • ‘Sponsor a National Missionary’
        • ‘Sponsor a Woman Missionary’
        • ‘Sponsor a Bridge of Hope Child’
      • And further down on the left-hand side, these ‘Donation Categories’:
        • Compassion Services’
        • ‘Empower the Poor’
        • ‘From the Stable’
        • ‘Major Ministries’
        • ‘Tools for Missionaries’
        • ‘Where Most Needed’
    • Why such a divergence in these two lists?
    • By the end of the year, GFAA said it had earned $2.29 million from
      • Total administration revenue’
      • ‘Empower the Poor’
      • ‘Emergency Relief fundraising program’
      • ‘Health and Medical fundraising program’
      • ‘Merchandise sales – books and tapes’
      • ‘Native Workers fundraising program’
      • ‘Social Justice fundraising program’
      • ‘Home Team Support’.
    • Why such a low correspondence with the giving options?
    • Money out of Australia
      • In the Notes to the Financial Statements, the reader is told that $1.92 million of donations were made for these items:
        • Compassion Services’
        • ‘Education’
        • ‘Emergency Relief’
        • ‘Empower the Poor’
        • ‘Missions, Tools & Support’
        • ‘Gifts and Donations’
      • This list matches none of the lists above.
    • Money into India
      • A double asterisk (**) at the bottom of Note 3 says that
        • Gospel for Asia (Australia) Inc. has an agreement with GFA India, a registered NGO in India, to distribute donations in accordance with the donors’ intent.
        • Was the money received by ‘GFA India’? If GFA India has complied with Indian law, the answer is given by inspecting a report that it must file with the Indian Government by 31 December each year for the year ended 31 March.
        • There is no such filing for the 2016 year. Nor is there a quarterly return for the last quarter of the Australian financial year. This is because GFA India changed its name to Ayana Charitable Trust sometime before October 2016.
        • However, the return shows no money coming from Australia (i.e., GFAA). This is because, like last year, the money was not sent to GFA India / Ayana Charitable Trust, but to another organisation, Believers Church.
        • The Indian returns show that GFAA sent approximately $2.12 million in the year ended 31 March 2016 and approximately $1.19 million in the quarter ending 30 June 2016. GFAA ‘Donations’ expense for the year ended 30 June 2016 was $1.92 m.
          • With, at the most, three transfers in a 15 month period, GFAA are open to the same finding as made by the ECFA: transfers were not frequent enough, ‘particularly given the urgent nature of many GFA gift solicitations’.
          • And the money not used quickly enough: in today’s dollars (10 August 2017) the Gospel for Asia entities in India, including Believers Church, were holding $151. 46 million of donors money in the bank.
      • So, quite contrary to the reasonable expectation of Australian donors, GFAA has sent all donors’ money to a church.
        • The money was donated for specific projects described as projects controlled by a ministry called Gospel for Asia (GFA); first they tell the donors that the money has been sent direct to a ministry in India without explaining the relationship between that ministry and Gospel for Asia; then it transpires that the money didn’t go to that ministry, but to the parent organisation in India, a church.
        • But not to any church, but a church with practices, for instance ring kissing and a communion liturgy, that appear to be un-evangelical. And practices that, for at least some donors who are donating to spread the Gospel may not be completely comfortable with, and which, when they came to light, contributed to the resignation of Gospel for Asia board members, including a 30-year veteran.
      • Was the money used for the purposes for which Australian donors gave it?
        • GFAA, unlike many charities, addresses this question:
          • Gospel for Asia (Australia) Inc. has an agreement with GFA India, a registered NGO in India, to distribute donations in accordance with the donors’ intent.…All donations are transferred to the field through GFA International offices including a detailed breakdown of donations outlining how they are to be distributed [Note 3].
          • The Indian return no long gives the use of the money beyond ‘Religious’ and ‘Social’ (see above), but in 2013-14 the return shows that the purpose of Australian donations included $488K for hospital construction, $138K for environment programs, and $54K for the celebration of national events, none of which were a donation option on the website[4].
        • The same Note attempts to give donors confidence in the use of their donations in India:
          • GFA India is audited internally by certified auditors, and also by Indian Government auditors to ensure all funds received are used in accordance with the transfer details and directions sent by international offices.
          • This confidence is only warranted if (a) the ‘transfer details’ matched donor intentions – and the evidence from the ECFA is that they didn’t – and (b) the donors could rely on the auditors.
          • Internal auditors are part of management’s internal controls, so that’s good. But they are not independent, so give limited comfort to Australian donors.
            • Do they really mean internal auditors?
            • Indian government auditors? I can find nothing to support the claim that the Indian government audits Believers Church[5].
        • GFAA’s membership of Missions Interlink means that it must (a) “ensure that (funds sent overseas) are used in a manner consistent with the charitable purposes of the Member” (Accreditation Standards) and (b) use “designated funds according to designated purposes” (Standards). The information presented raises serious doubt about GFAA’s compliance with these standards.
        • Missions Interlink Standards require that “All communications designed to raise funds shall avoid creating a false impression and be truthful as to fact, description and time frame” (Standard 3). Apart from the likely contravention in soliciting for one purpose then spending on another (see above), both the speed of sending donations and the speed of using them once they arrive do not match the sense of urgency for souls and needs painted in the promotional materials. (There is a good description of this issue in this article.) Standard 3 is therefore contravened.
        • GFAA says that ‘One hundred percent of contributions for use on the mission field are sent to the nations we serve and we have trusted the Lord to provide for our overhead costs’. But even if nothing is deducted from the donation in Australia before it reaches ‘the nations we serve’, are there any deductions in the spending country for overhead? Yes, there are.

Do they pay their directors?

  • The constitution does not address this. (Nor the reimbursement of directors’ expenses.) There is nothing in the Financial Report to suggest that GFAA pays its directors.

Is their reporting up-to-date?

  • Yes (four months after their year-end, a week earlier than last year).
    • This means that the next financial report is due by 31 December 2017. Before that the financial information on the Register will be up to 18 months out-of-date, so if you might, especially if giving a large donation, want to ask for more up-to-date information.

Does their reporting comply with the regulator’s requirements?

  • AIS (Annual Information Statement) 2016: No
    • The ‘Description of charity’s activities and outcomes’ is not a description of GFAA’s activities and outcomes, but a description of what they say happens overseas.
    • There is no evidence that GFAA ‘conducted activities’ in all states of Australia.
    • It was not the ‘General community in Australia’ ‘Who was helped most by the charity’s activities in the reporting period’.
    • There is no evidence that GFAA conducted activities in any of the five countries listed.
    • ‘Cost of sales’ has been incorrectly disclosed.
  • Financial Report 2016: No
    • There is no ‘Responsible Persons’ declaration’.
    • GFAA money goes to an organisation in India that is controlled by Gospel for Asia. Apart from having its long-time, and much-prized membership of the ECFA terminated, Gospel for Asia, since early 2016, been subject to a major lawsuit alleging misuse of donations. There is no mention of this in the Financial Report.
    • The directors have again prepared special purpose financial statements, statements that did not need to comply with all the Australian Accounting Standards, statements that the Australian standard setters have deemed not suitable for those people who rely on GFAA’s financial statements as their major source of financial information.
    • Again, the directors have not given their reason for this. For a professionally-managed organisation receiving $2.28 million from thousands of donors all over Australia, they are effectively saying that anybody interested in GFAA, for whatever legitimate reason, has the capacity to command the preparation of financial statements tailored to their needs. This is not credible.
    • Not all the figures in the prior year column in the Statement of Comprehensive Income match those that were published last year.
    • The Statement of Changes in Equity is again non-compliant with the Accounting Standards.
    • They continue to hold a large percentage (34% this year) of their cash in an account called ‘Online Saver – Trust’ without any mention, in the Financial Report or on the website, of a current trust.
    • They have again
      • calculated gross profit incorrectly.
      • omitted ‘Other comprehensive income for the year, net of tax’.
      • used a mixed classification of expenses.
      • omitted many necessary Notes.
        • Including the disclosure of related parties.
      • made no distinction between interest received and interest earned.
      • omitted to say which subset of Accounting Standards they have followed.

What financial situation was shown by that Report?

  • Last year’s 9% surplus as a percentage of revenue was over halved to 4% this year.
    • There was a 22% drop in donations, including a 31% reduction in ‘Home Team Support’.
  • Apart from ‘Cash assets’ of $707K, all items are under $27K, so GFAA is in a sound financial condition.

What did the auditor say about the financial statements?

  • The auditor, Jim Rawlings, of Hooper Accountants, gave a ‘clean’ opinion[6].
    • But this is despite agreeing with the directors’ decision to produce special purpose financial statements (see ‘Financial Report 2016’, above).
    • Because of a discretion exercised by the ACNC Commissioner, this auditor, because he is the auditor of an incorporated association, does not have to meet the higher qualification standard that would be otherwise required for a charity of this size. And he doesn’t.

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

  • Yes

Who are the people controlling the organisation?

  • Not shown on the website.
    • In fact, no director’s name appears anywhere on the the website.
  • The ACNC Register (under ‘Responsible Persons’) has these five:
  • Monica is shown as the Public Officer. A Public Officer is not automatically a responsible person, so the board may actually have only four members.
  • The board is one short of the number required by the constitution (two if Monica is not a member.)
  • For a charity receiving $2.29 million in public donations, the composition of the board is highly questionable:
    • Geoff and Monica Darr are a couple. Arguably the board therefore is too small. If Nick and Yvonne Bewes are similarly connected, then there’s no question that it’s too small.
    • Even without this issue, having two (or is it more?) employees (the Darrs) on a board of only five is risky for members and donors.
    • GFAA is therefore contravening Mission Interlink’s Accreditation Standard 3, the requirement to “have a board structure that provides for a demonstrated satisfactory composition.

To whom is GFAA accountable?

  • GFAA displays the ‘missions interlink ACCREDITED MEMBER’ logo, for instance, here. Membership confirmed.
    • Missions Interlink is the closest we have in Australia to the ECFA. Missions Interlink says that
      • Member use of the Missions Interlink logo implies high standards of governance and financial accountability, giving the Christian public assurance of their integrity.
      • On 27 August 2015, I sent a link to my previous review to the National Director, Pam Thyer, suggesting that GFAA was in breach of one or more of their standards. On 3 December 2015, Pam said that she had discussed the matters I raised in the review with GFAA and had concluded that ‘they do not contravene the MI Standards’.
  • As a registered charity, GFAA is accountable to the ACNC.
  • Also accountable to the regulator of Queensland incorporated associations.

 

 

 

  1. GFAA is a legal entity separate to Gospel for Asia in the US. However, there is ample evidence to suggest that the substance of the relationship is akin to head office and branch. See the previous review.
  2. They don’t do it, though, in the way the constitution goes on to describe: ‘recruiting, training and sending national workers  providing free primary schools to the slum children of India and Asia  Provide relief assistance and teach basic preventative medicine to those caught in poverty, sickness and hopelessness  providing relief assistance in times of natural disaster’.
  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. Here’s a similar list for all the monies from Gospel for Asia worldwide. The divergence between donor intent and spending was significant enough for it to be one of the reasons the Evangelical Council for Financial Accountability (ECFA) had for terminating Gospel for Asia’s long-standing membership.
  5. This claim, on the website when I last reviewed GFAA, is no longer there: ‘The financials and operating practices of Gospel for Asia India are rigorously audited by independent authorities in India to confirm that funds are dispersed to the areas of ministry designated by the donors and sponsors of Gospel for Asia (Australia) Inc.’
  6. To take the right amount of comfort for this finding, please read here and here.

 

Every Home Global Concern Limited: mini charity review

Mini charity review of Every Home Global Concern Limited (EHGCs an organisation that seeks donations online[1], and that 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.

Is EHGC responsive to feedback?

  • I sent a draft of this review to them on 1 August 2017. Like last year, they….did not respond.

Is it registered?

  • As a charity, yes.
  • As a public company, a company limited by guarantee.
    • Because it allows the payment of directors’ fees, it is not permitted to omit ‘Ltd’ on the end of its name.
  • For GST, yes.
  • It has a fundraising licence in all the states that require one.
  • EHGC has one registered business name.
    • There is a separate website under this name.
  • But EHGC still trading under the name ‘Global Concern’ without it being registered.
    • The relationship between the two entities is described in the Annual Report:
      • Every Home Global Concern grew out of Every Home for Christ and two trading names came into being in 2—8 – “Every Home for Christ” and “Global Concern”. Global concern reflects our second goal which is to help the poor and disadvantaged overseas lift themselves out of poverty through community development programs [emphasis in original].

What does EHGC do?

  • The ‘Description of charity’s activities and outcomes’ in the Annual Information Statement (AIS) 2016 merely directs the reader to one of EHGC’s two websites. Apart from being totally inadequate, this response leads to only half the picture. For there is another side to EHGC, shown in the other website, www.everyhomeforchrist.org.au.
    • The first website has only two indirect references to Every Home for Christ.
  • The first website, Global Concern, says that
    • For over 30 years, Global Concern has been providing opportunities for disadvantaged individuals and communities around the world to build better lives for themselves through education, healthcare, vocational training and micro enterprise. Far from being a handout, Global Concern aims to transform entire communities towards self sufficiency (sic) and sustainability. We don’t simply send money to overseas organisations and hope for the best, we closely monitor every one of our projects and give you the assurance that your investment is effectively addressing extreme poverty at its core.
    • Under ‘Projects’ in the main menu there are six links, but only one leads to information (on the work in Bangladesh).
    • The link to the ‘Annual Report’ is broken on the Global Concern site, but there is an annual report on the Every Home for Christ site.
      • Rather than being on the evangelism activities of EHGC, it is on the development activities described on the other website.
  • The second website, Every Home for Christ, describes EHGC as ‘a Christian Missions Organization dedicated to reaching every home on earth with the Gospel of Jesus Christ. We have works in 100 countries.’ This is therefore a description of the worldwide organization, not of EHGC.
  • EHGC apparently can ordain people – the Executive Director is an ‘Ordained Minister of Every Home for Christ’.

Do they share the Gospel [2]?

  • To the extent that your donation goes to fund work under the name Every Home for Christ, yes. If it goes to development work, no.
  • Even though $571K was spent on evangelization last year (Summary Financial Report), there is no online facility for donating to it (see below).
  • There is no statement of faith on either website.
    • Nor in the governing document. The governing document doesn’t even mention Christianity. Therefore, EHGC, via its membership of Missions Interlink, must
      • be able to demonstrate from its historical documents that its theological basis is not in conflict with the Statement of Faith of the Australian Evangelical Alliance. (Appendix 1)
      • These documents do not appear to be publicly available.

What impact are they having?

  • Nothing systematic found. Some anecdotal evidence in the Annual Report.

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

  • EHGC has itself calculated ‘administration’ as 25% of expenses. This is defining ‘direct’ as ‘Overseas support’.
    • The figure for ‘Accountability and Administration’ in the Summary Financial Report (in the Annual Report) is considerably less.

Can you get a tax deduction?

  • Only if you donate to its overseas aid fund, Every Home Global Concern Ltd Australia Overseas Aid Fund.
    • This means that if you donate via this page, your donation will go to overseas aid projects. You will therefore not be funding the sharing of the Gospel.

Is their online giving secure?

  • Global Concern
    • Security is not mentioned.
    • There is also a gift catalogue; the security could not be checked because the page requires a password.
  • Every Home for Christ
    • Security is not mentioned.

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

  • Global Concern
    • On this page:
      • None until you get to the second page.
        • ‘Where needed most’
        • ‘Malawi Project’
        • ‘Zambia Project’
        • ‘’India Project’
        • ‘Togo Project’
        • ‘Bangladesh Project’
    • On this page:
      • All those above, plus ‘Brazil Projects’.
  • Every Home for Christ
  • It appears from this, and the Financial Report 2016, that no work is carried out other than overseas. However, the Summary Financial Report (in the Annual Report) shows ‘Domestic Programs Expenditure…’ of $293K.

Do they pay their directors?

  • They can (their governing document, ‘Memorandum’, page 4), and they do (Note 5, financial statements).
    • $69K between two directors.
      • Up from $62K and one director last year.
    • Once appointed, EHGC directors serve for their lifetime (Articles of Association, governing document, ACNC Register).

Is their reporting up-to-date?

  • Yes (five months after their year-end, three weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS (Annual Information Statement) 2016: No
    • A website address is not a ‘Description of charity’s activities and outcomes’.
    • Four of the eight substantive figures in the ‘Comprehensive Income Statement summary’ are do match the figure in the financial statements.
      • ‘Grants and donations made for use outside Australia’ includes ‘Overseas projects supervision’ $109K.
  • Financial Report 2016: No
    • Note 1 first says that the report is a general purpose financial report, then contradicts that by listing only those Accounting Standards that are applicable to special purpose financial statements.
      • The auditor has a similar contradiction.
      • The content of the Notes is more consistent with special purpose statements.
    • There is a very strong connection between the parallel New Zealand organisations, Every Home Global Concern Incorporated and Every Home for Christ New Zealand: Eric Leach is the Executive Director of both the Australian and New Zealand Every Home for Christ organisations, 50% of the board are also members of the Australian boards (including the Chairman and Vice-Chairman). Despite this, there is no mention of the relationship – in fact there is no related parties disclosure at all.
    • 83% of the expenses are represented by the unexplained ‘Other Expenses from Ordinary Activities’.
      • This would include most of the money sent overseas. There is no audited disclosure of to whom the money is sent.
    • The accrual flows statement is labelled Statement of Profit or Loss and Other Comprehensive Income, but still has no ‘Other Comprehensive Income’ section.
    • The Statement of Changes in Equity again doesn’t comply with the Accounting Standards.
    • The 190% increase in the value of the Penhurst property that has been recorded resulted from a valuation that was done two months after the year end.
    • In Note 12 ‘Net income from fundraising’ is $1.19 m on page 15, then ‘Net surplus from fundraising on the next page is $614K.
    • Most, if not all, of the other questionable items last year are unchanged this year.

What financial situation was shown by that Report?

  • Last year’s 1% surplus as a percentage of revenue became a deficit of 14% of revenue this year.
  • Both short-term and long-term structure appear sound.

What did the auditor say about the financial statements?

  • The auditor, Tony Gilbert, of WSC Group of gave a ‘clean’ opinion[3].
    • However, see ‘Financial Report 2016’, above.

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

  • Yes
    • Global Concern, under ‘Other Name(s)’is a name by which they are known, but it is not registered.
    • For a company of this size, why is the auditor, Tony Gilbert, the ‘Charity Address for Service’?

Who are the people controlling the organisation?

  • They are listed on both websites.
    • The Global Concern website shows seven directors.
    • The Every Home for Christ website shows the same seven plus mentions an eighth, Setatow Befekadu.
  • The ACNC Register (under ‘Responsible Persons’) has these eight, plus Richard Snellenburg:
  • Three of these directors. James, Leach, and Thomas, have been on the board since the inception of the company in 2008. Directors serve for life.

To whom is EHGC accountable?

  • EHGC claims, on both its sites (here and here), accreditation with AusAid/DFAT and ACFID. Confirmed, and confirmed. Both have an accountability regime.
  • There is no mention, on either site, of their membership of Missions Interlink, an organization that, at least nominally, requires accountability.
  • As a registered charity, EHGC is accountable to the ACNC.

 

 

  1. On both its websites: www.everyhomeforchrist.org.au/donate, and twice on www.globalconcern.org.au (on the home page, and again, with different information, here.)
  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. 
  3. To take the right amount of comfort for this finding, please read here and here.