Kids Outreach International Limited: charity review

This is a charity review of Kids Outreach International Limited (KO), an organisation that seeks donations via the internet[1] and is a member of Missions Interlink. (Including the answers to the questions that the charity regulator, the ACNC, suggests that you ask.)

For last year’s review, see here.

Are they responsive to feedback?

  • There is no invitation to give feedback or make a compliant on the website, nor anything about accountability.
  • I sent them a draft of this review. Like last year, they….did not respond.

Is KO registered?

  • As a charity, yes.
  • KO is a public company, a company limited by guarantee.
  • Names:
  • Fundraising:
    • There’s a licensing regime for charities in six states. KO, per the ACNC Register, operates in four of them: New South Wales, Queensland, Victoria, and Western Australia. (It also operates in the ACT.)
    • KO doesn’t have any fundraising licences. It doesn’t mention licensing on its website or in its Financial Report 2016. Does it believe that it is exempt?

What do they do?

  • These projects.
  • What they said they did in 2016 (via their Annual Information Statement (AIS) 2016):
    • 1. Facilitated teams of volunteers to live in Russian summer camps to provide cultural exchange, life skills education and broadening the horizons of the Russian children and their carers/camp counsellors. 2. Financial assistance to families who have adopted disadvantaged children. 3. Raised funds for victims of sex trafficking that are supported by an organisation in Finland. 4. Commenced negotiations for cross-cultural, spiritual and lifeskills education programs in Estonia with local partners. Pilot program to be delivered in 2017.

Does KO share the Gospel?[2]

  • It appears from a search of ‘gospel’ on the website that individuals on the trips overseas do.

What impact are they having?

  • Nothing systematic found.

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

  • If we define ‘direct’ as ‘Specified Projects’ plus ‘Outreach Project’ (both unexplained in the accounts), then it cost $91K to deliver $56K. That’s 62% for ‘administration’.

Do they pay their board members?

  • The constitution prohibits this.
  • There’s insufficient disclosure in the Financial Report 2016 to conclude on such payments.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • The online giving offered, via GiveNow, does not mention security.

Is their reporting up-to-date?

  • Yes (lodged six months after their year-end 10 days later 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 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite. No outcomes given.
  • Financial Report 2016: Yes[3]
    • Because of its size (‘Small’), KO is not required to submit a Financial Report.  It has, however, chosen to submit one anyway. But because it was a voluntary submission, the Report does not need to comply with the ACNC’s requirements.  (And it doesn’t.)
    • However, their 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.” Missions Interlink do not define ‘appropriate’, but compared what a professional accountant would produce (and a professional auditor or reviewer would require), again,
      • Two of the four required financial statements are missing.
      • The Income Statement does not comply with the Accounting Standards.
      • There is no declaration by the directors.
      • The disclosure is not consistent with the type of statements – general purpose – claimed.
        • Including no mention of related parties.

What financial situation was shown by that Report?

  • The surplus as a percentage of income went backwards again, from positive 3% to negative 3%.
    • The 22% decline in revenue was more than compensated for by a reduction in ‘Employment Expenses’ of 36%.
  • $33K is held in ‘Cash and cash equivalents’ but is offset by short-term payables of $20K (including the unexplained ‘Funds held on behalf of FH40’ and ‘Funds held on behalf of SUAS’).
  • There are no long-term liabilities, so the long term financial structure is OK.

What did the auditor say about the last financial statements?

  • The auditor, Mark Hosking, concluded from his review – not an audit – that ‘nothing has come to our attention that causes us to believe that the annual financial report…does not present fairly in all material respects the financial position…and…financial performance…This provides a lower level of comfort than a ‘clean’ opinion[4].
    • Before you decide how much comfort to take from this opinion, please re-read the comments under ‘Financial Report 2016’, above.

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

  • Not quite. ‘Phone’ and ‘Website’ are blank. (But the ACNC say that neither are compulsory.)

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

  • The two that are mentioned on the website are sponsorship of somebody going to Russia and going yourself.

Where were your (net) donations sent, and what ensures that they are used for the purposes given?

  • Not disclosed.

Who are the people controlling the organisation?

  • Not shown on the website, but the ACNC Register lists them under ‘Responsible Persons’:
    • John Donovan
    • Antti Haavisto
    • Ross Kelly
    • Taru Kohonen
    • Kari Lehelma
    • Roger Nicoll
    • Risto Rummukainen

To whom are KO accountable?

  • As a charity, to the ACNC.
  • The Missions Interlink ‘Accredited Member’ logo is at the bottom here. Membership confirmed.
    • Missions Interlink is an organisation that has standards with which KO must comply, but, as a comparison of this review with the review last year shows, it appears that at least the reporting standards are either much lower than professional standards or can be treated with impunity.
  • Accountable, for some things still, to ASIC.

 

  1. On its websites (www.kidsoutreach.org and www.stepupagainstslavery.org) by inviting you to make a transfer to its bank account, or online via GiveNow.
  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. I was wrong last year. I didn’t realise that if a charity that wasn’t required to submit a Financial Report submitted one, it did not need to comply with the ACNC’s requirements for such reports.
  4. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Interserve Australia Inc: charity review

This is a charity review of Interserve Australia Inc (Interserve), 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.)

This the second review of Interserve. You can see the first here.

Are they responsive to feedback?

  • Interserve does not invite, on its website, either feedback or complaints.
  • I sent them a draft of this review. They…did not respond.

Is IT registered?

  • As a charity, yes.
  • Interserve is a Victorian incorporated association (No. A0025704J).
    • It operates, per the ACNC Register, in all eight states.
      • Interserve has an office for Victoria/Tasmania in Melbourne, and another for NSW/ACT in Sydney. It also has a name and email contact for each of South Australia, Western Australia and Queensland/Northern Territory.
      • And an invitation on the internet to give.
    • It has the registration necessary to operate interstate (ARBN 108 918 823).
    • It has a fundraising licence in NSW, but not in the other five states that have a licensing regime applicable to charities. It does not mention fundraising licences on the website, nor in the Financial Report 2016.
  • Interserve does not hold any business names. It therefore should not be trading under any name other than its legal name. Not Tangible Love, Interserve, CultureConnect or Interserve Australia[1].
  • Interserve operates, per the ACNC Register, in Bangladesh, Cambodia, India, Nepal, and Pakistan. But in the Director’s (sic) Report [Financial Report 2016] they say they are in ‘more than twenty countries’.
    • On the website, it’s six regions, and four ‘partners’ (missionaries).

What does Interserve do?

  • Start here, and then follow the links at the bottom of the page.

Does Interserve share the Gospel?[2]

  • Via some of its missionaries, no doubt.

What impact are they having?

  • Nothing systematic found.

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

  • There’s a figure for ‘Administration expense’, but if we define direct as the money sent to the missionaries (‘Partners Expenses’), that figure is clearly just a subset of ‘administration’, and ‘administration’ is 61% of expenses.

Do they pay their board members?

  • There’s nothing against this in the constitution.
  • There’s insufficient disclosure in the Financial Report 2016 to conclude on such payments.

Can you get a tax deduction?

  • No, not Interserve itself. However, you can for a donation to its fund, Interserve Overseas Aid Fund.
  • This is recognised in the answer to a ‘Giving FAQ’ on the website:
    • In Australia, a tax deduction can be claimed for donations to certain types of work only. Donations supporting Interserve Partners working in community aid and development are paid into our Overseas Aid Fund and are tax-deductible. Donations supporting Partners doing non-development work (such as theological education, classroom teaching or pastoral work) are not tax-deductible. Other income received by Interserve – including unallocated donations, income from special appeals and bequests – is paid into the Overseas Aid Fund and is tax-deductible for the giver.
      • However, it isn’t possible to tell which workers do work that is eligible for a tax deduction when you give via the website.

Is Interserve’s online giving secure?

  • At the bottom of the page there’s the GeoTrust logo, so yes.

Is their reporting up-to-date?

  • Yes (five and a half months after their year-end, a week later than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly 15 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • The ‘Description of charity’s activities and outcomes’ is not particularly about 2016.
    • Several of the financial figures do not match those shown in the financial statements.
    • Money is sent to missionaries yet ‘Grants and donations made…’ is shown as zero.
    • Contrary to what is said in Section D, the financial statements do not include more than one entity.
    • No outcomes are reported.
  • Financial Report 2016: No, a true and fair view is not shown.
    • For a charity with revenue of $4.63 m (primarily donations), operating all over Australia and in five (twenty+ ?) countries overseas, and with 112 staff, the directors’ decision for another year that Interserve does not have any users, past or prospective, ‘who are dependent on its annual financial statements’, is implausible. The result, special purpose financial statements again, implies that all its users can command the preparation of a report tailored to their needs. Not believable.
    • The classification of both revenue and expenses has been completely changed without any explanation.
    • Interserve has a ‘Specific purpose donations’ (expense, not revenue) of $241K. This is their explanation:
      • Specific purpose donations are designated gifts received for partners. In 2015, the designated gift fun was classified as a reserve. In 2016, the directors have established that there is a constructive obligation to their partners hence the directors have resolved to move the balance of the reserves to liability through the statement of profit or loss.
      • There is no explanation of how moving a credit balance from a reserve to a credit balance in liabilities results in an expense.
      • The disclosures required by the Accounting Standards are missing.
    • There is no explanation of the distinction between employees and ‘partners’.
    • The Statement of Cash Flows is incorrect: dividends and interest should be disclosed separately, the figure for ‘Receipts from suppliers’ is incorrect, and just three line items is inconsistent with the purpose of the statement.
    • There is an unexplained difference of $115K between what is shown as revenue for 2015 this year compared to last year’s accounts.
    • 95% of the revenue is in items that are not explained.
      • What is the relationship between the revenue ‘Team support funds’ and the expense ‘Partners expenses”?
    • Four of the six largest expenses that produce the ‘Surplus for (sic) operating activities’ need an explanation: ‘Partners Expenses’, ‘Gift fund expenses’, Culture Connect Expenses’, and ‘International expenses’.
    • There is no explanation for the borrowings that existed last year being absent from the accounts this year.
    • The amount received for the tax-deductible Fund is again not disclosed.

What financial situation was shown by that Report?

  • Ignoring the ‘Specific purpose donations’ expense (see above), the surplus as a percentage of revenue increase from less than one percent to 3%.
  • Current assets are 5.9 times current liabilities.
  • ‘Cash and cash equivalents’ plus ‘Financial assets’ equals ten and a half months’ revenue.
  • $726K is held in shares (not expected to be sold within 12 months), a relatively risky asset class. No information on this portfolio is given.
  • Long term assets are 1.5 times long term liabilities.

What did the auditor say about the last financial statements?

  • The auditor, Peter Shields, for Saward Dawson Chartered Accountants, issued a ‘clean’ opinion. To take the right amount of comfort for this finding, please
    • read here and here to learn about opinions, and
    • re-read the information above on Interserve’s financial reporting.

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

  • Yes

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

  • ‘Tangible Love’ [directed to a separate website]
  • ‘Donate now’
    • ‘Interserve Worker’
    • ‘General donation – area of greatest need’
    • ‘CultureConnect’
    • ‘Care for Kids Education (COKE) Fund’
    • ‘Action in Mission (AIM) Fund’
    • ‘Other’
  • ‘Give regularly’
    • The same options as above.

Where were your (net) donations sent, and what ensures that they are used for the purposes given?

  • Not disclosed.

Who are the people controlling Interserve?

  • Not shown on the website. But the ACNC Register (under ‘Responsible Persons’) says it’s these people:
    • Antonius Buntsma
    • Ricky Campbell-Allen
      • Is it this Ricky Campbell-Allen?
    • Wesley Cassidy
      • Is it this Wesley Cassidy?
    • Joel Erkkila
      • Is it this Joel Erkkila?
    • Greg Horth
    • Allan Mathews
      • Is it this Allan Mathews?
    • Alison Morgan
      • Is it this Alison Morgan?
    • Andrew Prince
      • Is it this Andrew Prince?
    • Ruth Thorne

To whom is Interserve accountable?

  • Their answer has its own page:

  • The ‘National Council’: incidental references on the website imply that this is the board of directors. But the board is Interserve, not a body to which Interserve is accountable. They describe the relationship correctly elsewhere:

  • The ‘accountability’ page is the only place where they mention ‘State committees’.
  • As they say on this page, they are accountable (as a charity) to the ACNC.
    • The seal they show is called the ‘charity tick’. It means that Interserve is registered as a charity, its AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • Missions Interlink membership confirmed.
  • The logo, The Micah Network, indicates membership, membership that provides no accountability.

 

 

  1. There is an unrelated company called Interserve Pty Ltd. The business name Culture Connect Australia is held by Culture Connect Pty Ltd, and CulturalConnect is held by an individual.
  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.

International Teams Ministries Australia Incorporated: charity review

This is a charity review of International Teams Ministries Australia Incorporated (IT), 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.)

Last year’s review is here.

Are they responsive to feedback?

  • They do not, on the website, invite either feedback or complaints.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is IT registered?

  • As a charity, yes.
  • IT is a New South Wales (NSW) incorporated association (Y2915020).
  • It operates, per the ACNC Register, in Queensland as well as its home state of New South Wales. It also has an invitation to give on the internet.
    • It still doesn’t have the registration necessary, an ARBN, to operate interstate.
    • It says that it has a fundraising licence (see below). It doesn’t say where, but it is in NSW. But it doesn’t say why it doesn’t have one in Queensland, or in the other three states that have a licensing regime applicable to charities:

  • It holds three business names in its current name:

  • And one in its former name: International Teams Australia.

What does IT do?

Does IT share the Gospel?[1]

  • Via some of its missionaries, no doubt.

What impact are they having?

  • Nothing systematic found.

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

  • No figure for ‘administration’ is given, and the expenses are not classified so as to allow a figure to be calculated.

Do they pay their board members?

  • There’s nothing prohibiting this in the constitution.
  • There’s no line item in the expenses that suggests that such payments were made.

Can you get a tax deduction?

  • No
    • But the ‘Give’ section on the website incorporates the tax-deductible fund International Teams Australia Sydney Refugee Team (see ‘Is IT registered?’, above).

Is IT’s online giving secure?

  • Security is not mentioned.

Where were your (net) donations sent?

  • This is not disclosed. Even the country.

Is their reporting up-to-date?

  • Yes (six months after their year-end, two days before the deadline, and two weeks later 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 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • Group AIS 2016: No
    • ‘Employee expenses’ again only includes wages.
    • ‘Other Income’ doesn’t match the Income and Expenditure Statement.
    • No outcomes are given.
  • Group Financial Report 2016: No, the accounts do not give a true and fair view. Like last year (and, in most cases, the year before that too):
    • The Report is still missing a statement of cash flows.
    • The Report is still a ‘special purpose financial report’. This is only applicable where the organisation’s users, both present and prospective, can command the preparation of statements tailored to their needs. For an organization with an income of nearly $1 m, 306 staff, missionaries in 10 countries, and seeking donations from the public, this is implausible.
      • The directors again give no reason for their decision.
    • The name of the charity on the cover has a subheading ‘Sydney Refugee Team’, but this is not explained anywhere.
    • The statement of changes in equity is titled Income and Expenditure Statement.
    • The Income and Expenditure Statement uses a long out-of-date format, and consequently omits ‘Other Comprehensive Income’.
      • There no Notes. For instance, what is the second largest income item, the unusual ‘Global Services Funding’ ($127K).
        • This item, without explanation, is zero this year.
        • $80K for one full-time and three part-time employees?
    • In the Detailed Balance Sheet –
        • ‘Web design and development at cost’ an intangible, is misclassified.
        • The non-current ‘Provision for Web site (sic) upgrade’ is questionable as a liability.
    • The number of Notes has been increased again but is still well short of the number required.
    • The Statement by Members of the Committee is again undated.
    • There is no explanation of the status of the missionaries (they are not included as employees).
    • The person who ‘compiled’ the statements – see below – again makes the basic bookkeeping mistake of equating ‘Cost of Sales’ with ‘Gross Loss from Trading’.
    • The figures include cents, potentially confusing the communication.
    • There are unexplained ‘appropriation adjustments’.
    • What accounts for the proportionately large balance of ‘Trade creditors’?
    • And new this year –
        • A long-superseded accounting term, ‘extraordinary items’ is resurrected to describe an unexplained prior period adjustment.
        • Unidentified ‘capital gains’ have been included in the surplus.

What financial situation was shown by that Report?

  • I do not have enough confidence in the accounts – see above – to pass comment on this. The fact that the accounts were prepared by the auditor – the inclusion of a Compilation Report tells us that – only reinforces this decision.

What did the auditor say about the last financial statements?

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

  • Group: Yes
  • IT: Not quite – the business names are missing.

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

  • ‘Where Most Needed’
  • ‘Specific Worker’
    • ‘Other Worker’ + 10 individuals/couples (including two in ‘National Office’)
  • ‘Specific Project”
    • ‘OTHER Project’
    • ‘Nea Zoi, Athens’
    • ‘RenovArte Café, Mexico’
    • ‘Rroma-Workers Network’
    • ‘StreetLight, Sydney’
    • ‘Sydney Refugee Team (tax deductible)’
    • ‘Threads of Hope, Athens’

Who are the people controlling IT?

  • The people shown on the website here.
  • The same people as are shown on the ACNC Register (under ‘Responsible Persons’):

To whom are IT accountable?

  • As a charity, to the ACNC.
  • Membership of Missions Interlink claimed on the website, for instance here:

    • Membership confirmed.
    • Missions Interlink is an organisation that has standards with which IT must comply.
      • For one opinion on the strength of this accountability, see the section Activities in this review.
  • Christian Ministry Advancement Ltd is the organisation that is, via the CMA Standards Council, giving a seal of approval to Christian organisations who meet “a set of standards of good governance, financial oversight, and fundraising ethics.” IT is not yet accredited.

 

 

  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.

The European Christian Mission (Australian Section) Incorporated: charity review

This is a charity review of The European Christian Mission (Australian Section) Incorporated (ECM), an organisation that seeks donations online, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

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

Are they responsive to feedback?

  • ECM do not invite, on their website, feedback or complaints.
  • They do not mention accountability on the website.
  • I sent them a draft of this review. They…did not respond. [Last year they promised a response, but it didn’t come.]

Is ECM registered?

  • As a charity, yes.
  • ECM is an ACT incorporated association (A 00256).
  • But its office is in NSW, and it operates, per the ACNC Register, also in Victoria. It has the necessary registration (ARBN 054 215 388) to operate interstate.
  • Since it has no business name registered, ECM shouldn’t operate under any name other than its full registered name, as above. Not as
    • ecm Australia on its office
    • ECM Australia – New Zealand, ECM, and ECM Australia and New Zealand on its webpage, and
    • ECM and European Christian Mission Australia on its Facebook page.
  • ECM doesn’t have a fundraising licence in either of the states in which it operates. Nor in any of the others that have a licensing regime. This licensing is not mentioned on the website.

What do they do?

  • “The ECM office in Australia is working with a dedicated team of office staff, Council members and volunteers for the selection, sending and support of missionaries. In addition, the office mobilizes Christians in Australia and New Zealand to help build a different Europe, through prayer and financial support [from the website].

Does Empower share the Gospel?[2]

  • Via the missionaries, 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?

  • The expenses are not classified to allow this calculation.

Do they pay their board members?

  • There’s nothing prohibiting this in the constitution.
  • There’s no line item in the expenses that suggests that such payments were made.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

Where were your (net) donations sent?

  • This is not disclosed. Even the country.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • The ‘Type of financial statements prepared’ is incorrect.
    • Why ‘No’ to ‘Financial report submitted to a state/territory regulator?’?
    • ‘Other Income’ and ‘All other revenue’ are incorrect.
    • No outcomes given.
  • Financial Report 2016: No. A true and fair view is not shown.
    • It appears that ECM controls the equivalent New Zealand organisation, European Christian Mission. But there is no explanation for the lack of consolidation of the New Zealand figures with those of ECM. (ECM merely says, in Note 10, that they provide ‘administrative services for the New Zealand operation’, and duplicates the financial information that is in the ‘Annual Return Summary for that charity on the New Zealand register of charities.)
    • The directors don’t say, but if we go by what the auditor says, they decided to produce special purpose financial statements, rather than the type that comply with all the Accounting Standards. This type is only appropriate if no user, present or prospective, is dependent on standard financial statements to make decisions. Which is stretching plausibility for an organisation that has 28 employees (27 of whom are full-time), operates in two states, collected $804K from givers, and calls for donations on its website.
    • A true and fair view is threatened by several other issues.

What financial situation was shown by that Report?

  • There are too many issues with the Financial Report to make reliable comment.

What did the auditor say about the last financial statements?

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

  • Yes

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

  • None if giving online, these if not:

  • The missionaries are shown on the Australian webpages, but not the projects.

Who are the people controlling the organisation?

  • There are Council members shown under ‘Staff and Trustees’ on the website.
  • The list on the ACNC Register (under ‘Responsible Persons’) is somewhat different. It includes Romeo Dinale and excludes Louise George, Wendy Mugridge, Jennifer Jones, and Brett Richardson:
    • Romeo Dinale
    • Peter Dixon
    • Guy Freeman
    • Matthew George
    • Peter Jones
    • Madeleine Koo
    • Alan Mugridge
    • Ruth Richardson
    • The name ‘Peter Jones’ appears on the register for 30 charities. And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  If after eliminating the charities for which ECM’s Peter Jones 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.
  • ECM say the Council is a combined one for ‘ECM Australia and New Zealand’:

    • This may be the way they think about it, and talk about it, but there are actually two separate charities, one registered in Australia, the other in New Zealand. And they have separate boards.

To whom are ECM accountable?

 

 

  1. Its two officers are ECM board members.Its street address is ECM’s street address.Its phone number is ECM’s phone number.

    Its shares a website with ECM.

    The constitution that ECM has lodged covers both charities.

  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.

Empower Australia Overseas Aid Fund Inc: charity review

This is a charity review of Empower Australia Overseas Aid Fund Inc (Empower), an organisation controlled by Empart Inc (a Missions Interlink member), and that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • About Us’ begins with this though:
    • EMPOWER is a not-for-profit that subscribes to a high standard of accountability and stewardship.
  • When sent a draft of this review, they…did not respond.

Is Empower registered?

  • As a charity, yes.
    • Empower is controlled by Empart Inc[1]. But there is no mention of Empart on the website, or in the Financial Report 2016.
  • Empower is a Victorian incorporated association (VIC A0047253K).
  • It is using the names Empower and Empower Overseas Aid Fund without them being registered.
  • Empower operates, per the ACNC Register, in all states except Northern Territory.
    • It has the registration necessary to carry on business interstate (ARBN 621 279 445).
    • Under ‘About Us’, Empower records how it has responded to the existence of state-based fundraising legislation: of the six states that have a fundraising regime that is applicable to charities, Empower says that it is registered in five (Queensland, New South Wales, Victoria, Tasmania, and South Australia), but doesn’t mention the sixth (Western Australia).
      • The registrations for all bar Tasmania are confirmed. For Tasmania, Empower says ‘Approval to Solicit for Charitable Donations’. However, they are not in the Tasmania government’s ‘List of approved charities in Tasmania’.
      • You’ll find links to each regulator’s website on the left hand side here.

What do they do?

  • Empower says that it ‘exists to equip, educate and empower those suffering sickness, poverty, destitution and misfortune through sustainable community transformation projects in developing countries.’ It doesn’t do this itself, but through local partners. Instead, it is about ‘Transferring funds or goods overseas’ [Annual Information Statement (AIS) 2016].
  • Empower operates overseas, per the ACNC Register, in India and Nepal.
    • Only India is mentioned under ‘Projects’ in the main menu.

Does Empower share the Gospel?[2]

  • 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?

  • If ‘Designated Expenses’ means the money sent to India (as the AIS 2016 implies), then it cost $91K to send $600K. That’s 13% for ‘administration’.
    • But give that they share an office with their parent entity, and have no property, plant and equipment, how much ‘administration’ is borne by that entity?

Do they pay their board members?

  • There’s nothing prohibiting this in the constitution.
  • There is insufficient disclosure of expenses to check for such a payment.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

Where were your (net) donations sent?

  • This is not disclosed. Even the country.
  • From my internet research two years ago, I found the following organisations associated with Empart, and therefore organisations who could be recipients of the money:
  • From the returns lodged with the Indian Government, we can see that Australian donors’ money was received by the last two of these: CFI Ministries in Chandigarh and CFI Charitable Trust in Orissa.
    • The returns submitted by these two organisations, when combined, show that approximately $472K was received in the year ended 31 March 2017. This compares to $600K recorded by Empower for ‘Grants and donations made…for use outside Australia’ in the AIS 2016 in the year ended 31 December 2016. This $128K difference may be due, apart from minor translation differences, to the three-month difference between the two years in question. Just ask them.
  • Whatever the amounts, you might also ask them what procedures ensure that your donation will be used for the purpose you have designated.
  • ‘Cash and Cash Holdings’ (what’s the difference?) in Australia increased dramatically (without explanation) from $80K to $387K. Even so, it seems reasonable compared to the amount of cash that is held by the two recipients of the Australian donations in India: $701K. That’s a lot of Indian purchasing power.
    • With an organisation that is required to model Jesus as Lord and Saviour to the poor and oppressed of India, it would be legitimate for you to ask Empower why they hold this much.

Is their reporting up-to-date?

  • Yes (five and a half months after their year-end, one and a half months later 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 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • $58 K for ‘Employee expenses’ doesn’t match the reporting of nine employees (three of whom are full-time).
    • Why ‘No’ for ‘Financial report submitted to a state/territory regulator?’?
    • The financial statements are described incorrectly.
    • The description of activities is not about Empower, but what is done by other organisations overseas.
    • No outcomes are given.
    • Its own name is included under ‘Other names charity is known by…’.
  • Financial Report 2016: No. Not a true and fair view.
    • One of the four required financial statements is missing.
    • Both the Income Statement, and the Statement of Financial Position are a long way sort of what is required.
    • Even though Empart collects donations on behalf of Empower, they share an office, and the directors are six of the eight directors of Empart, Empower doesn’t mention of the relationship.
    • The directors have, without giving their reasoning, elected to prepare special purpose rather than general purpose financial statements. This choice, a choice that means that not all the Accounting Standards have to be followed, is only correct if no user, present or prospective, is dependent on standard financial statements to make decisions. For an organisation that operates in seven out of eight states, had a turnover of $752K, and seeks donations from the public, this is stretching plausibility.
    • ‘Amounts written back equity’ is included without explanation, and, counter-intuitively, as a cash flow.
    • ‘Designated’ donations are, without explanation, recorded as a liability.

What financial situation was shown by that Report?

  • The condition of the Report (see above) means that it is difficult being anywhere near definitive, so I’ll pass.

What did the auditor say about the last financial statements?

  • The auditor, Ben Tardrew CPA, of Tardrew Partners, gave a ‘clean’ opinion.
    • But because of what I have identified above, he shouldn’t have done. (See here and here to learn about opinions.)
    • Ben is only qualified to do this audit because of the ACNC’s transitional provisions for reporting by incorporated associations:  the Victorian regulator doesn’t require the audit of Empower to be performed by a registered company auditor.

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

  • No
    • There is a message ‘Charity to select subtype’, and
    • Empower’s legal name is not an ‘Other Name…’

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

  • ‘Safe Water – Wells’
  • ‘Street Children’
  • ‘Safe Home’
  • ‘Toilets’
  • ‘Schools’
  • ‘Agricultural Development’
  • ‘Where Most Needed’

Who are the people controlling the organisation?

  • It says, on the website, that there is a board, but the members are not shown.
  • The ACNC Register, under ‘Responsible Persons’, says that its these people:
    • Jan de Bruyn (just ‘Bruyn’ as the last name)
    • Brian Holmes
    • Markus Koch
    • Paul Lambert
    • Daniel Muggeridge
    • Peter Sypkes
    • All these directors are also directors of Empart.

To whom are Empower accountable?

  • As a charity, to the ACNC:

  • The logo is the ACNC’s ‘charity tick’.  Apart from saying that Empower is registered with them, the ‘tick’ also means that Empower’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • The ACNC’s standards are part of the ongoing obligations as a registered charity.
  • Empower is not, as it says, a ‘large Charity’, but a ‘Medium’ one. This means that it could have a review rather than an audit.
  • Empower is also accountable to the Victorian regulator of incorporated associations.

 

 

  1. Empart does not produce consolidated financial statements. It does not explain why. (Empower is not even mentioned in the accounts.) Empart has not taken advantage of the ACNC’s group reporting concessions.
  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.

Empart Inc: charity review

This is a charity review of Empart Inc (Empart), an organisation that seeks donations online, is member of Missions Interlink, and that you might know through the ‘motivational speaking’ of its founder, Jossy Chacko:

 

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

To see the situation last year, read this review.

Are they responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • The ‘Accountability’ page begins with this though:
    • Empart is a non-profit charitable organisation that is committed to maintaining a high level of accountability and transparency.
  • And the Empart USA website says that
    •  In each country we seek not only to comply with governmental requirements but we also submit to independent evangelical accountability groups.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is Empart registered?

  • As a charity, yes.
    • Empart controls another charity, Empower Australia Overseas Aid Fund Inc[1].
      • Empart does not produce consolidated financial statements. It does not explain why. (Empower is not even mentioned in the accounts.)
      • On its website, Empart merely refers to the Fund as a ‘partner’ that provides the ability to get a tax deduction.
      • Empart has not taken advantage of the ACNC’s group reporting concessions.
  • Empart is a Victorian incorporated association (A0034935L).
  • It is still using the names Empart and Empart Australia without them being registered.
  • Empart operates, per the ACNC Register, in all states.
    • It has the registration necessary to carry on business interstate (ARBN 621 279 329).
    • For its fundraising licences, see the last question below.

What do they do?

  • Contrary to the information on the website (‘What we do’ in the main menu), and what they report under ‘Description of charity’s activities and outcomes’ in their Annual Information Statement (AIS) 2016, Empart is not itself involved in good works in South Asia (or anywhere else). As it says for ‘International activities’ in the AIS, it is about ‘Transferring funds or goods overseas’.
  • Empart operates overseas, per the ACNC Register, in India and Nepal.

Does Empart share the Gospel?[2]

  • No

What impact are they having?

  • Nothing systematic found. (Nor on the work in South Asia.)
  • At the bottom of the ‘Accountability’ page, Empart makes this offer:
    • On request, Empart will gladly send you the latest Partnership Impact Report, free of charge.
    • If it is the report that Empart USA produces, then the latest one that is available on their website is for 2014.

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

  • The functional (except for ‘Employee benefits expense’) classification of expenses in the Financial Report does not allow this calculation.
  • However, from the disclosure of ‘Grants and donations made…’ in the AIS 2016, and defining ‘direct’ as 100% of that money[3], we can see that it cost $946K to raise and send $1.22 m overseas. That’s ‘administration’ of 44%.

Do they pay their board members?

  • There’s nothing prohibiting this in the constitution.
  • There is insufficient disclosure of expenses to check for such a payment.

Can you get a tax deduction?

  • The ABN register says no.
    • Which is contradicted under ‘What we do/Sustainable solutions’ on the website:
      • We have specific field projects that qualify for tax deductible giving. These projects all provide ongoing sustainable solutions to long term problems…. For more information please phone the office on 03 9723 9989 or use the Contact menu.
        • The explanation is in the ‘NB’ after that:
      • This means that you will be giving your money to Empower, not Empart. After completing a (draft) review of Empower, I’d suggest caution.

Is their online giving secure?

Where were your (net) donations sent?

  • This is not disclosed. Even the country.
  • From my internet research two years ago, I found the following organisations associated with Empart, and therefore organisations who could be recipients of the money:
  • From the returns lodged with the Indian Government, we can see that Australian donors’ money was received by the last two of these: CFI Ministries in Chandigarh and CFI Charitable Trust in Orissa.
    • The returns submitted by these two organisations, when combined, show that approximately $964K was received in the year ended 31 March 2017. This compares to $1.22 m recorded by Empart for ‘Grants and donations made…for use outside Australia’ in the AIS 2016 in the year ended 31 December 2016. This $256K difference may be due, apart from minor translation differences, to the three-month difference between the two years in question. Just ask them.
  • Whatever the amounts, if it is still the case that ‘no formal reconciliations were received from the India office regarding how the monies received were disbursed’, as the auditor reported last year[4], this means that you have no assurance that your donation will be used for the purpose you have designated.
  • The $1.27 m in ‘Cash Assets’ held in Australia is not explained, but it seems reasonable compared to the amount of cash that is held by the two recipients of the Australian donations in India: $701K. That’s a lot of Indian purchasing power.
    • With an organisation that is required to model Jesus as Lord and Saviour to the poor and oppressed of India, it would be legitimate for you to ask Empart why they hold this much.

Is their reporting up-to-date?

  • Yes (five and a half months after their year-end, one and a half months later 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 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • Why ‘No’ for ‘Financial report submitted to a state/territory regulator?’?
    • For the third year in a row, the financial statements are described incorrectly.
    • There are again mismatches between the financial information and the accounts.
    • The description of activities is not about Empart, but what is done by other organisations overseas.
    • No outcomes are given.
  • Financial Report 2016: No. Not a true and fair view.
    • Even though Empart collects donations on behalf of Empower, they share an office, and the directors are six of the eight directors of Empart, there is no mention of the relationship.
    • The directors have again, without giving their reasoning, elected to prepare special purpose rather than general purpose financial statements. This choice, a choice that means that not all the Accounting Standards have to be followed, is only correct if no user, present or prospective, is dependent on standard financial statements to make decisions. For an organisation that operates all over Australia, had a turnover of $2.21 m, has 26 staff, and calls for donations on its website, this is stretching plausibility.
    • ‘Amounts written back equity’ is again included without explanation, and again, counter-intuitively, as a cash flow.
    • ‘Designated’ donations are still, without explanation, recorded as a liability.
    • Empart is still not depreciating its property, plant and equipment.
      • Their explanation for this (in Note 1) shows a misunderstanding of the applicable Accounting Standard.
    • All loans, $667K, including ‘Private Loans’[5] of $253K, are shown as non-current. The repayment terms for the loans are not disclosed. A repayment was made last year. Should some (or all?) be shown as current (with implications for the working capital position)?
    • The other comments in last year’s review are still applicable.

What financial situation was shown by that Report?

  • The condition of the Report (see above) means that it is difficult being anywhere near definitive, so I’ll pass.

What did the auditor say about the last financial statements?

  • The auditor, P.J. Igoe CPA, of P.J.Igoe & Associates, gave a ‘clean’ opinion.
    • But because of what I have identified above, my opinion is that he shouldn’t have done. (See here and here to learn about audit opinions.)
    • Phillip is only qualified to do this audit because of the ACNC’s transitional provisions for reporting by incorporated associations:  the Victorian regulator doesn’t require the audit of Empart to be performed by a registered company auditor.

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

  • Yes

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

  • ‘General support’
  • ‘Transforming Communities’
  • Transformation Centres’
  • ‘Bike for a Worker’
  • ‘Sewing Machine’
  • ‘Children’s Homes’
  • ‘Wells’
  • ‘Mercy homes ministry’
  • ‘Field Worker Support’
  • ‘Field Worker’s Kit’
  • ‘Women’s ministry’
  • ‘Children’s ministry’
  • ‘Schooling for a child’
  • ‘Toilet blocks’

Who are the people controlling the organisation?

  • They say, on the website, that they have a board, but don’t give the membership.
  • The ACNC Register, under ‘Responsible Persons’, says that its these people:
    • Jan de Bruyn (just ‘Bruyn’ as the last name)
    • Jennifer Chacko
    • Jossy Chacko (the subject, not the painter):

To whom are Empart accountable?

  • The ‘Accountability’ page on the website declares three accountabilities: ‘non-profit organisation’, ‘state fundraising registrations’, and ‘external accountability’.
  • The first one is about it being a registered charity:

    • The ACNC’s standards are part of the ongoing obligations as a registered charity.
    • The logo is the ACNC’s ‘charity tick’.  Apart from saying that Empart is registered with them, the ‘tick’ also means that GI’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • Under the second, Empart records how it has responded to the existence of state-based fundraising legislation:
    • Of the six states that have a fundraising regime that is applicable to charities, Empart says that it is registered in four, is exempt in one (South Australia), and doesn’t mention the sixth (Western Australia).
    • It is registered in Queensland, New South Wales, Victoria and Tasmania. You’ll find links to each regulator’s website on the left hand side here.
  • First under ‘external accountability is Missions Interlink:
    • Here’s the ‘MI Standards Statement’.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • Second under ‘external accountability is this logo, following by a glowing testimonial:

  • They got the seal after ‘a comprehensive assessment of Empart’s governance, strategy, finances, impact and communication and technology. This included on-site visits to our ministry in the field.’
    • Certification confirmed.
    • Unlike the first three logos though, this one comes from a US organisation, and, despite the contact person being Jossy Chacko in Australia, from the testimonial it is clear that it is not specifically Empart that was assessed, but the wider organisation.
      • It would be interesting to see how Empart would fare against the transparency standards:
        • Transparency seal recipients voluntarily disclose debt levels, Board engagement, 3-year program and financial trends, impact stats, strategic plans, and even an internal S.W.O.T. analysis (Strengths, Weaknesses, Opportunities, and Threats). 
  • Empart is also accountable to the Victorian regulator of incorporated associations.

 

 

  1. Empower is not a member of Australian Council For International Development (ACFID).
  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. That is, ignoring the fact that there would be some costs of administration after it arrived in the overseas country.
  4. In a letter to his client that should not have been included in the Financial Report.
  5. Last year the auditor reported, in a letter that was not meant to be lodged, that the documentation for these loans was deficient.

Christian Women Communicating International: charity review

This is a charity review of Christian Women Communicating International (CWCI), an organisation that has an internet invitation to give, 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.)

For last year’s review, see here.

Are they responsive to feedback?

  • I sent them a draft of this review. Like last year, they did not respond.

Is CWCI registered?

  • Yes, as a charity.
  • The name they are using, CWCI International, is still not registered. (They don’t hold any business names.)
  • CWCI operates, per the ACNC Register, all over Australia. It has no State fundraising licences. Even if it doesn’t require any because its physical fundraising doesn’t qualify, what about its internet invitation?

What does CWCI do?

Do they share the Gospel?[1]

  • Not their mission.

What impact are they having?

  • The only information is what is in the AIS2016: ‘This [Bible studies] advances the Christian religion.

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

  • No financial information is available.

Do they pay their board members?

  • There’s nothing against this in the constitution.
  • There’s no financial statements to check for such a payment.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • It’s broken. When working, it’s via PayPal, so yes, it is secure.

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

  • None

Is their reporting up-to-date?

  • Yes (on the last day, six months after their year-end, the same time as last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Yes
  • Financial Report 2016: NA
    • As a Basic Religious Charity they exempt, an exemption that extends to completing ‘Section D Financial Information’ of the AIS.
    • 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?

  • 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/correct?

  • Except for their phone number, yes. (This, however, is not compulsory.)

Where were your (net) donations sent?

  • No financial statements to check. Nothing on the website.

Who are the people controlling the organisation?

  • No names on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Margaret Gardner
    • Heather Jackson
    • Kaye Shooter
    • Lyn Taylor
    • Lisa Watson
    • The board is, compared to the constitution, short one member.
    • The name ‘Margaret Gardner’ appears on the register for 10 charities. And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  If after eliminating the charities for which CWCI’s Margaret Gardner is not a director, you are left with the total being near this number, it would be legitimate for you to question whether her ability to discharge her fiduciary responsibilities is threatened.

To whom is CWCI accountable?

  • As a charity, to the ACNC.
  • Membership of Missions Interlink claimed. Confirmed.
    • Missions Interlink has a set of standards that must be followed.
      • For one opinion on the strength of that accountability, see the section Activities in this review.

 

  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.

Crossculture Church of Christ Inc: charity review

A charity review of CrossCulture[1] Church of Christ Inc (CCC), an organisation that seeks donations online 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.)

For last year’s review, see here.

Is it responsive to feedback?

  • CCC does not invite, on its website, feedback or complaints.
  • There is nothing about their accountability on the website.
  • I sent them a draft of this review. Like last year, they… did not respond.

Is CCC registered?

  • As a charity, yes.
  • CCC is a Victorian incorporated association (VIC A0050619R).
  • It holds two business names, Melbourne City Conference Centre, and Celebration Books.
  • CCC routinely use less than its full name, thus contravening the business names legislation and, most likely, sometimes also their enabling (associations) legislation.
  • It is exempt from the Victorian fundraising regime. Whether it requires a licence in the other states that have a regime applicable to charities depends on whether those states think that CCC is ‘fundraising’.

What do they do?

Does DMI share the Gospel?[2]

  • 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?

  • This is too hard to estimate from the information provided.

Do they pay their board members?

  • There is no constitution on the ACNC Register to check whether this is prohibited.
  • Unless it is in one of the expense items called ‘Others’, it does not appear that they make such payments.

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?

  • Online, only ‘General Fund’ and ‘Open Up, Reach Out Project’.
  • By direct debit:

Is their reporting up-to-date?

  • Yes (six months after year end, two days before the deadline and three weeks later than last year.)

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • The figures for the ‘Comprehensive Income Statement summary’ are not the figures for CCC, but one of its ‘segments’.
    • The business names are missing.
    • There are no outcomes given.
  • Financial Report 2016: No. Once again,
    • The Report is a confusing collection of statements, several which are not required.
    • There is no ‘Statement of Comprehensive Income’, or similar.
    • There is no ‘Statement of Changes in Equity’, or similar.
    • The Notes to the Financial statements are incomplete.
    • By any reasonable interpretation, a church with a multi-million-dollar turnover and that controls two other charities is a reporting entity, and should therefore produce financial statements that comply with all the Accounting Standards.
    • There is no explanation of the relationship between the two charities that they control (Crossculture School Building Fund and Crossculture Development Foundation Ltd).
    • And, this year, where did the $10.28 m of ‘Property, plant & Equipment’ go?

What financial situation was shown in that Report?

  • Because of the issues with the Financial Report (see above), I make no comment.

What did the auditor say about the last financial statements?

  • The auditor, Brian Bay FIPA, of Brian Bay & Co, issued a ‘clean’ opinion. He shouldn’t have done – see Financial Report 2016, above.

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

  • No.
    • The three business names are missing.
    • ‘Operates in (Countries)’ is blank.
    • Still only one ‘responsible person’ is shown.

Where were your (net) donations sent?

  • There is a list of ‘Global Partners’ under ‘Expenditure’ in one of the financial statements (see above), but no locations.

Who are the people controlling the organisation?

  • Not shown on the website.
  • ‘Responsible Persons’ on the ACNC Register still shows only one person, Chuang Kong.
  • The pastors are shown here, but it appears from the Financial Report 2016, that the following people, the ‘Board of Elders’ are (or at least were on 7 May 2017) in charge:
    • Samuel Reeve
    • David May
    • Pieter Bruinstroop
    • Zyx Owen
    • Chee Khiam Tay
    • Thomas Siaw
  • We cannot confirm the composition of the committee because CCC still hasn’t lodged its governing document.
    • It has lodged an ‘Overview of the governance structure of Swanston Street Church of Christ’, but this document does not mention the committee required under the associations legislation (nor most other things required by that legislation).
  • Chuang Kong is neither a pastor nor, per the ‘Board of Elders Report’, an elder.

To whom is CCC accountable?

  • As a charity, to the ACNC.
  • And to the Victorian incorporated associations regulator.
  • Not claimed on the website, but CCC is also accountable to Missions Interlink via their Associate membership.
    • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. The name on the ACNC Register is incorrect: ‘CrossCulture…’, not ‘Crossculture’.
  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.

CityLife Church Inc: charity review

A charity review of CityLife Church Inc (CC) as an organisation that seeks donations online, whose ‘World Impact Dept’ is a member of Missions Interlink, and which shares a director (Karen Naylor) with the body that accredits organisations if they meet ‘Nine Principles of Ministry Accountability‘. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

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

Are they responsive to feedback?

  • I sent them a draft of this review. Like last year, they… did not respond.

Is CC registered?

  • As a charity, yes[1].
    • Not to be confused with the organisation with the identical name, a New South Wales association (INC9878332).
    • Or a name that’s close:
      • Citilife Church Inc (a deregistered Queensland association)
      • Citilife Church (a business name of Christian Outreach Centre)
  • CC controls four, probably five, and possibly six, other charities:
  • CC is a Victorian incorporated association (A0026171A).
  • It holds no business names. Does this mean that it should be using its full name on its website and on Facebook?
  • CC operates, per the ACNC Register, not only in Victoria but also in Western Australia. There is no mention of this state on the website. If they are indeed operating there, they do not have the necessary registration (an ARBN).
  • CC operates in eight overseas countries.
  • CC doesn’t have any fundraising licences. It is exempt in the state in which it operates. Whether it requires a licence in the five six states that have a licensing regime for charities depends whether they think that seeking donations on the internet is ‘fundraising’.

What do they do?

  • See under ‘Connect’ and under ‘Grow’ in the main menu on the website.

Does CC share the Gospel?[2]

  • Yes

What impact are they having?

  • Nothing systematic found.

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

  • The expenses are not classified to allow this calculation.

Do they pay their board members?

  • There nothing prohibiting this in the constitution.
  • Unless such expenses are included in ‘General Expenses’ (and barring misclassifications), no such payments have been made.

Can you get a tax deduction?

  • No
    • But under ‘Give’ in the main menu, both ‘Outreach’ and ‘Building’ options are tax-deductible giving. This is because CC is collecting for another charity.

Is their online giving secure?

  • Security is not mentioned.

Is their reporting up-to-date?

  • Yes (five and a half months after their year-end, the same time as 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 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • I cannot get a combination of CC’s multiple donation figures in the profit and loss statement to add to the figure given.
    • The ‘Gift from Open House Christian Fellowship’ $3.43 m, is not ‘Other Income (for example, gains)’.
    • No outcomes are given.
    • The trading name is missing.
  • Financial Report 2016: No. The accounts do not show a true and fair view.
    • CC is a very large church (Melbourne’s largest?). It has multiple sites, 114 employees, and 2584 volunteers (AIS 2016). And that’s ignoring its subsidiaries. Therefore, the directors’ claim that CC is not a reporting entity is…well, ridiculous.
      • The directors again do not give any reason for this decision, but it means that they can produce financial statements that do not have to comply with all the Accounting Standards. It also means that they are effectively saying is that CC has no users, past and prospective, who rely on normal financial statements to make decisions.
    • The Financial Report does not give the full picture of the CC operation. CC has four, probably five, maybe six active ministries that are run via separate charities yet does not produce consolidated financial statements.
      • CC says that ‘Kingdom Investment Fund…and Student Impact Fund are included as part of these financial reports’, but this appears to mean only that their transactions and balances are reported along with those of CC in the one set of statements.
        • For instance, to show ‘Distribution from KIF’ as a negative amount in CC’s accounts is confusing.
      • This extract from Note I (o) is an example of the integration in reality, but not in the accounts:

    • For more, see this footnote[3].

What financial situation was shown by that Report?

  • Because of what’s above, no comment.

What did the auditor say about the last financial statements?

  • The auditor, Peter Shields for Saward Dawson, gave a ‘clean’ opinion.
  • But before you decide how much comfort to take from this
    • note that in continuing with the engagement, he again implicitly agreed with the directors’ decision to produce special purpose rather than general purpose financial statements (see above).
    • see ‘Financial Report 2015’ above.
    • read here and here about audit opinions.

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

  • Are they really operating in Western Australia?
  • ‘Phone’ and ‘Website’ are still blank, but neither are compulsory.

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

  • ‘General’
    • ‘Tithes’
    • ‘General Offering’
    • ‘Church Building Fund’
    • ‘World Impact (Missions)
      • ‘Partnership in Missions’
      • ‘Other’
    • ‘Other’
  • ‘Nations’
    • ‘Partnership in Missions – Missions Worker’
      • ‘Please specify’ (no drop-down menu)
    • ‘Partnership in Missions – Other’
      • ‘Please specify’ (no drop-down menu)
  • ‘Outreach’
    • (‘Kingdom Investment Fund’) ‘My gift for where most needed’ (Tax-deductible)
  • ‘Building’ – ‘The Story Building Project’

Where were your (net) donations sent?

  • Other than ‘in Australia’, $2.13 m, and ‘for use outside Australia’, $569K (AIS 2016), there is no disclosure.

Who are the people controlling the organisation?

  • They are not shown on the website, but per the ACNC Register (under ‘Responsible Persons’):
    • Mark Eddison
    • Daljit Gill
    • Andrew Hill
    • Peter Leigh
    • Michael Loke
    • Karen Naylor
    • Peter Sheahan
    • Andrea Stickland
    • Elizabeth Thong
    • All these board members are also members of at least one of CC’s charities. Hill and Eddison are members of two, Sheahan three, and Leigh all four.
    • The name ‘Andrew Hill’ appears on the register for 12 charities. And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  CC’s Andrew Hill is the Senior Pastor of CC, so, if after eliminating the charities for which he 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 are CC accountable?

  • As a charity, to the ACNC.
  • And to the Victorian regulator of incorporated associations.
  • It’s not mentioned on the website, but a part of CC, its ‘World Impact Dept (sic)’ is a member of Missions Interlink. (It is strange that membership continues to be in this name, the name of an entity that doesn’t even have an ABN.)
    • Missions Interlink is an organisation that has standards with which members must comply.
      • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. The name has been recorded as ‘Citylife…’ instead of ‘CityLife…’.
  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. Other comments:
  • Other than the ‘Board of Elders’ (the committee), only ‘CityLife Community Care’ is mentioned under ‘Related Party Disclosure’.
  • CC again discloses a $4.48 m ‘contingent asset’:

  • A contingent asset is ‘a possible asset that arises from past events and whose existence will be confirmed only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of the entity [AASB137.10, www.aasb,gov.au].
  • Even though CC says that this distribution in the same class as ‘Tithes, offerings and other gifts’, and therefore should only be recognized on receipt, it is the Accounting Standard on revenue that governs when revenue is recognized. And in this case, because it is more than ‘probable’ that ‘future economic benefits will flow’ to CC, and the distribution can ‘be measured reliably’ [AASB 118, www.aasb.gov.au], this $4.48 m should, on the information presented by CC, have been booked as revenue. With an asset as the contra. Both assets and revenue are therefore materially understated.
  • The group has lent $6.00 m to Waverley Christian College, all of it at 90 day at-call or less. There is no explanation why this has been classified as a non-current asset.
  • As a public ancillary fund, Kingdom Investments can only help deductible gift recipients. CC is therefore not eligible. To whom was the money donated?
  • The presentation of income in the Statement of Income and Expenditure and Other Comprehensive Income is confusing and neither complies with the Accounting Standards nor matches what is shown in the Statement of Cash Flows.
  • CC continue to disclose ‘Revenue for General Reserves & KIF’ ($2.82 m) without explanation. It is the source of the revenue, not its destination that needs to be disclosed here.
  • CC continues to use the acronym ‘KIF’ without explanation.
  • ‘Other expenses’ $879K is broken down, but ‘Ministry expenses’, 983K, is again unexplained.
  • The unusual ‘Expense from General Reserve ($336K) is still unexplained.

Bible College of Queensland: charity review

A charity review of Bible College of Queensland (BCQ), an organisation that seeks donations online 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.)

The previous review, in 2016, is here.

Are they responsive to feedback?

  • BCQ does not, on its website, invite feedback.
  • I sent them a draft of this review. Like last time, they…did not respond.

Is BCQ registered?

  • As a charity, yes.
  • BCQ is a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
  • It has three business names, Brisbane School of Theology, Bible College of Queensland, and Centre for Asian Christianity.
  • BCQ operates in Australia, per the ACNC Register, only in Queensland. It solicits donations via the internet.
    • It has a fundraising licence only in Queensland. Whether it needs one in the other four states that have a licensing regime for charities depends on whether those states think that BCQ, by calling for donations on their website, are ‘fundraising’ in their State.
  • BCQ does not, per the ACNC Register, operate overseas.
    • Why then the membership of Missions Interlink, ‘the Australian network for global mission’?

What does BCQ do?

  • It’s in the name. For how they do it, start here.

Does BCQ share the Gospel?[1]

  • To students, undoubtedly. But the grant of tax-deductible status suggests that the use of the money raised shouldn’t include proselytising.

What impact are they having?

  • Nothing systematic found.

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

  • The expenses are insufficiently disclosed to allow an estimation of this.

Do they pay their board members?

  • This is not permitted under BCQ’s constitution.
  • There is insufficient information about the expenses to check for these payments.

Can you get a tax deduction?

  • Their ABN record says that you can. Both to BCQ itself, and to either of its two funds, Qld Bible Institute College Building & Maintenance Account, and Bible College of Queensland Library Fund.
    • But this is contradicted by the existence of a giving option (see below) that is not tax-deductible.

Is BCQ’s online giving secure?

  • Mycause.com.au is used, and security is not mentioned on their first page.

Is the reporting up-to-date?

  • Yes (five months after their year-end, over two months later 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 14 months in the past.

Does BCQ’s reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Other income’ is incorrect. (With a consequence that ‘All other revenue’ and ‘Total revenue’ are also incorrect.) It matches neither the ACNC’s definition, nor the accounts.
    • No outcomes are reported.
  • Financial Report 2016: Yes?
    • The items classified as ‘Other income’ are as much revenue as the items included under ‘Revenue’. Revenue is therefore understated by $201K.
    • There is still no explanation for the non-standard practice of separating ‘Building Improvements’ and ‘Building development costs’ from ‘Buildings’.
    • The disclosure of revenue still includes a combined revenue figure for ‘Student fees, board and functions’ $1.23m.
    • For other observations, see this footnote[2].

What financial situation was shown by that Report?

  • The surplus as a percentage of revenue (adjusted – see above) was still negative, at 3%, but down from last year’s 8%.
  • The wages bill is unchanged from last year’s 70% of expenses.
    • From the workforce disclosed in the AIS 2016, and assuming the casuals average 10% of full-time and the part-timers 50%, this represents an average package of $69K p.a.
  • The margin of current assets over current liabilities (working capital), declined from 1.8 times to 1.3 times.
  • The holding of land and buildings means that the long-term financial structure is sound.

What did the auditor say about the group’s last financial statements?

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

  • Except for the omission of one business name, yes.

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

  • ‘Give a gift to our General Fund to be used where it is needed most (not tax-deductible)’
  • ‘Support our Centre for Asian Christianity as we equip Christians for contextual Asian ministry’
  • ‘Make a tax-deductible gift and invest in our Library Fund’
  • ‘Make a tax-deductible gift and invest in our Building Fund’

Where were your (net) donations sent?

  • NA

Who are the people controlling BCQ?

  • Shown on the website here.
  • Which are the same people shown on the ACNC Register (under ‘Responsible Persons’):
  • The board is responsible to the members. There were 21 of these at 31 December 2017 (Directors’ Report, Financial Report 2016). As directors must be members (the constitution), 12 outside the board provides some accountability.

To whom is BCQ accountable?

  • As a charity, to the ACNC.
  • Not claimed on the website, but BCQ is a member of Missions Interlink, an organisation that has standards with which BCQ must comply.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • BCQ, as a company, is still accountable for some things to ASIC.

 

  • 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.
  • If interest is accrued (Note 1 a), why is the revenue identical to the cash amount?There is still no item in ‘Cash Flows from Operating Activities’ that includes the donations.Neither fundraising nor administration costs are disclosed.There is still no explanation for the unusual item ‘Rental of communication tower’ (7+% of revenue).

    One of the items of ‘Property, Plant and Equipment’ is still ‘Plant and Equipment’. What’s in it?

    The figure for provisions in Note 10 does not match the figures in the Statement of Financial Position.

    We are still not told (a) the functional and presentation currencies, and (b) whether the directors have the power to amend and reissue the financial statements.

    There’s still no policy Note ‘New, revised or amending Accounting Standards and Interpretations adopted’