Overseas Council Australia: charity review

This is a charity review of Overseas Council Australia (OCA), an organisation that invites the public to donate to it, and that is connected, through Stephen Kerr, to the CMA Standards Council, Christian Ministry Advancement Ltd‘s ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

(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.

Is it responsive to feedback?

  • Its own accountability is not mentioned on the website.
  • I sent them a draft of this review. They…did not respond.
    • OCA has a ‘Complaints Handling Policy’. Itsets out how we approach complaints or negative feedback about us.’

Is it registered?

  • Yes, as a charity.
  • OCA is a public company, a company limited by guarantee.
    • It is entitled to omit ‘Limited/’Ltd’ from the end of its name.
  • OCA is a member of an ACNC ‘reporting group’. There’s one other member of the group, The Trustee For Overseas Council Fund (the Fund)[1]. They are a member because OCA is the trustee.
  • Both charities operate, per the ACNC Register, all over Australia. And OCA solicits donations online. However, OCA is only registered as a fundraiser in its home state, NSW, and in South Australia. They give no explanation for the absence of licences in the other four states that have a licensing regime for registered charities.

What does OCA do?

  • Here’s their strategy:
    • Choose the best theological college within a context, with strong governance and accountability: support the college with funding and resources, to enable it to do what it does best, so that the college in turn becomes an enabler and leader to other neighbouring colleges to assist them to become leaders and enablers to others also. Through this process thousands of new leaders are trained each year for work in the church as pastors, evangelists and church planters.

Do they share the Gospel[2]?

  • No. (It funds the training of those that will).
    • There is no mention of evangelism in the ‘Statement of Faith’, and the constitution doesn’t even mention Christianity

What impact are they having?

  • Nothing systematic found.
  • The latest Annual Report on the website is for 2016.

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

  • If we define ‘Payments and in kind (sic) allocations to Projects’ as these direct costs, then 28% was ‘administration’.

Do they pay their directors?

  • This is not disclosed.
  • There is insufficient public information to say.

Can you get a tax deduction?

  • No
    • This is contradicted on the ‘Giving to Growth’ page:

Is their online giving secure?

  • GeoTrust is used, so yes.

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

  • Where most needed’
  • ‘Student support’
  • ‘Faculty support’
  • ‘Infrastructure project’
    • You will need to know the name of the project
  • ‘Translation or commentary project’
    • You will need to know the name of the project
  • Africa Bible Commentary’
  • If you are giving a tax-deductible donation, you are donating to the Fund. In that case, you are effectively donating to other charities. See the next section.

Where were your (net) donations sent?

  • This is not disclosed.
  • For your donations to the Fund, here are the intended destinations:

Is their reporting up-to-date?

  • Yes (two weeks late, six and a half months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Group Annual Information Statement 2017 (Group AIS 2017): No
    • ‘General community in Australia’ is not the group that was helped most.
    • There is one less state shown than on the Register entries for the group members.
    • ‘Donations and bequests’ does not match the financial statements.
    • No outcomes are reported.
  • Group Financial Report 2017: No.
    • There is no reason given for reducing short-term liabilities by 98% – 943K – by converting them to equity.
    • The surplus in the income statements is again not the same as the surplus in the Statement of Changes in Equity.
    • ‘Prior year adjustments’ are again included in the Administration Reserve without being explained.
    • Any why are there ‘Prior year adjustments’ in the Statement of Cash Flows?
    • ‘Increase in borrowings’ in included in ‘Investing Activities’ in the Statement of Cash Flows.
    • Not only do the directors continue to produce the lower standard special purpose financial statements, but they continue to think that no explanation is required. For a charity with an income of $2.13 m, most of it from donations, operating in all states, and in 30 overseas countries, operating a public ancillary fund, and with 12 staff, it is not plausible that all stakeholders, both present and prospective, can command OCA to produce a report tailored to their needs.
    • Two income statements are again, without explanation, included. And both continue to omit ‘Other comprehensive income’. As does the Statement of Changes in equity[3].

What financial situation was shown in that Report?

  • By a reclassification of liabilities to equity (see above), OCA has fixed it negative working capital (current liabilities exceed current assets), and negative equity, issues of last year.
  • The ‘net income’ as a percentage of ‘income’ has declined from 6% to less than 1%.

What did the auditor say about the last financial statements?

  • The auditor, Lawrence R Green, FCA, of Shedden and Green Partners, issued a ‘clean’ opinion on the financial statements.
  • But before you decide how much comfort to take from this opinion,
    • note that he has omitted an essential paragraph in his report. It is especially important in the case of OCA, because as usual OCA includes an extra income statement, and the paragraph is the one that identifies what the auditor audited,
    • read the ‘Financial Report 2017’ section above, and, if you are still relying on the opinion after that,
    • read here and here to understand what ‘clean’ means.

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

  • OCA: Almost – ‘General community in Australia’ is not the group that was helped most.
  • The Fund: ditto
  • The Group: The same question is blank.

Who are the people controlling the organisation?

  • The nine people introduced on the website here.
  • The ACNC Register (under ‘Responsible Persons’) has the same names:
    • John Allison
    • John Anderson
    • David Brown
    • Kenneth Chapman
    • Miyon Chung
    • Sandra Clarke
    • Timothy Clemens
    • Alan Jeffrey Hall
    • Stephen Kerr
    • There are 26 directorships recorded for the name ‘John Anderson’, 21 for ‘David Brown’, and eight for ‘Kenneth Chapman’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities that don’t belong to the OCA director, you are left with his total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.
  • The Fund doesn’t have ‘trustees nominated from the OCA board’, as it says above, but, because OCA is the trustee, the entire OCA board are the ‘responsible persons’ for the Fund.
  • The board is responsible to the members. Having 64 members [Directors’ Report] provides some accountability.

To whom is OCA accountable?

  • As charities, both OCA and the Fund are accountable to the ACNC.
  • And, as a company, OCA is still accountable for some things to ASIC.
  • OCA displays the Missions Interlink ‘Member’ seal:

    • Membership confirmed[4].
    • Missions Interlink has an accountability regime.
      • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. The name is missing ‘The’ (Overseas…).
  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. In addition, there is again insufficient disclosure in the first section of the Statement of Cash Flows, ‘Donations received’ in Note 6 does not match the statements, the Notes to the accounts are again missing some that are customarily included, and restricted donations are not shown.
  4. Missions Interlink is not though, the ‘peak body of churches, ministries and missions’. It is only about ‘missions’, and only has 103 ‘Members Organisations’.

 

Malyon College (Queensland Baptists): charity review

This is a charity review of Malyon College (MC), an organisation that seeks donations online[1], 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?

  • There is no invitation on the website to give feedback, nor an invitation to submit a complaint other than if you are a student, and no discussion of accountability as an organization.
  • I sent them a draft of the review. Like last time, they… did not respond.

Is MC registered?

  • Although MC is a charity, it is not a charity registered with the charities regulator, the ACNC. It would no doubt argue that this is the reason for the lack of registration:

  • Although they have omitted it from their ABN record, ‘Queensland Baptists’ is a registered business name of The Baptist Union of Queensland (BUQ), which is a registered charity.
  • MC presents to the world as a separate entity – own website, own premises – so you might expect that it has its own ABN (and then uses that to register as a charity). The fact that it doesn’t is OK so long as it operates under the same ‘business structure’ as The Baptist Union of Queensland:

  • So, MC has no separate legal identity – it is not incorporated. Instead, it is a department or division of BUQ.
    • BUC is incorporated though – under an archaic mechanism called ‘letters patent’. Its letters patent is under an old Act, The Religious Educational and Charitable Institution Act of 1861 (Qld).
  • For BUQ to be able to operate under a name Malyon College (that is, a name other than its own (full) name), it must register a business name. It’s got 27 names registered, but Malyon College – The Queensland Baptist College of Ministries is the closest it’s got to Malyon College. This means that MC not entitled to trade under the names it uses, on both its website and Facebook, Malyon College and Malyon[2].
  • BUQ (and therefore MC) operates, per the ACNC Register, only in Queensland. It said in its AIS 2017 that it did not intend to fundraise. It therefore ignored the fact that MC (and maybe other departments) have an online invitation to give. If it believes that it meets the definition of a ‘religious order’ in Queensland, or that it is a body that has ‘an authority to marry people’ in Victoria, then its lack of a fundraising licence anywhere in Australia is explained for those two states, but what about the others?

What do they do?

  • We provide world-class, accredited theological education and train our students in practical ministry, so they can serve God effectively wherever God places them[3].
  • BUQ operates overseas, per the ACNC Register, only in Solomon Islands. There is nothing on the MC website to suggest that it is MC that is in this country.
  • MC doesn’t have a constitution to check for objects or purposes, but BUQ’s By-Laws tell us that a ‘Purpose Statement’ for MC should have been developed. There is one reference to such a statement on the website, but the document is not there or elsewhere on the internet.

Do they pay their board members?

  • MC should have a Charter. It’s not available publicly so I can’t check for a provision about paying board members.
  • There is insufficient public financial information to say.

Do they share the Gospel[4]?

  • Yes, but you would expect their audience to already be believers.

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 is insufficient disclosure to even estimate this.

Can you get a tax deduction?

  • No, you can’t for a donation to BUQ itself, only its two funds. So that means that you can’t get one for a donation to MC either.
  • But this does not match the information on the website:

  • As it says further down that page, this is via a donation to The Malyon Foundation.
    • The Trustee for the Malyon Foundation is a registered charity, not a department of BUQ. It is a public ancillary fund, with three individuals as the ‘trustee’.
    • It can only give gifts to an organization that has deductible gift recipient status. MC doesn’t have this, so why is MC collecting directly for its own operations?

Is their online giving secure?

  • It is not offered.

Where were your (net) donations sent?

  • No information is available.

Is their reporting up-to-date?

  • Yes (via BUQ) (over eight months after their year-end, five weeks late, and six 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 nearly 11 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: NA – MC is not a registered charity.
  • BUQ AIS 2017: No
    • All but one of the business names is missing. And the name The Malyon Foundation.
    • The activities are not specifically those of 2017.
    • No outcomes are reported.
    • It would be surprising if the number of employees were exactly 800, 300, and 100.
    • They will be fundraising next year.
    • It is surprising that there was no ‘Other income’ in $110.84 m of income.
    • ‘Other comprehensive income’ is incorrect.
  • Financial Report 2017: NA – MC is not a registered charity.
    • But as a member of Missions Interlink MC 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].
      • There is no evidence that MC produces such a statement.
      • Even if a financial statement for the organization of which MC is a department, BUQ, is acceptable to Missions Interlink, that financial statement needs to be ‘clear and appropriate’.
  • BUQ’s Financial Report 2017, like last year, is neither ‘clear’ nor ‘appropriate’.
    • To claim that there are no users, present or prospective, who are dependent on a regulator to get the financial information that might need to make decisions about an organization that has multiple public-facing departments, and 3200 staff, is…ludicrous.
    • The directors still behave as if they believe that they are above the law – for an organization of this size and complexity run professionally it must be this rather than mere ignorance – in that they continue to
      • omit one of the required financial statements,
      • produce a Statement of Profit or Loss and Other Comprehensive Income that is materially non-compliant with the Accounting Standards, and
      • consolidate one charity they control yet leave another out (without mentioning consolidation).
      • do several other things that are contrary to a true and fair view.

What was the financial situation shown by that Report?

  • Given what is reported above, no comment.

What did the auditor say about the last financial statements?

  • There are no separate financial statements of MC available. So, no audit.
  • The auditor of BUQ, Glen Klein CPA, of Audit Right Pty Ltd, issued a ‘clean’ opinion[5]. Looking at what is reported above, one must ask ‘Why?’

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

  • NA – MC is not a registered charity.
  • For BUQ, no, it’s not:
    • All but one of the business names is missing. And the name The Malyon Foundation.
    • ‘Who the Charity Benefits’ is blank.
    • ‘Phone’ and ‘Website’ are blank (but neither is compulsory).

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

http://malyon.edu.au/about-us/support-malyon/

Who are the people controlling the organisation?

To whom is MC accountable?

  • As a department of BUQ, MC is accountable to BUQ.
  • MC doesn’t mention it, but it is a member of Missions Interlink.
    • See the section Activities in this review for one opinion on the strength of this accountability.

 

 

  1. For another charity, The Trustee for The Malyon Foundation.
  2. Although BU has another 26 business names, it does not show any business names on the Australian Business Register. Nor does it have its four ‘centres’, the Malyon Centres, registered.
  3. http://malyon.edu.au/about-us/
  4. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14. 
  5. Read here and here to draw the right conclusions from such an opinion.

 

Praxeis: charity review

This is a charity review of Praxeis, 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 the review. Like the last two years, they did not respond.

Is Praxeis registered?

  • Yes, as a charity.
  • Also as a public company (a company limited by guarantee).
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
  • Praxeis wasBirthed and commissioned by’ Crossway Baptist Church Inc., and there is nothing to indicate on either website that the connection has been severed[1].
  • Praxeis operates, per the ACNC Register, in seven states (up from five last year). It says in the AIS 2017 that it intends to fundraise in four of those states, and seeks money online, but doesn’t explain why it has no fundraising licences.

What do they do?

  • These are their ‘core activities’:
    • continual, passionate and persevering prayer,
      always
      sharing the good news of Jesus with lots of people,
      inviting people to the exciting and challenging journey of
      following Jesus (making disciples),
      creating simple and reproducible
      communities that live out the message of Jesus (simple Church),
      creating a movement of people that virally spread the message and
      multiply.
      These are the things we focus on and do again and again.

      • Sounds like what an evangelical church, like Crossway, should be doing. So why is it being done by a para-church organization?
  • Although not mentioned under ‘About’, and therefore easy to miss, more specific information can be found under the main menu item ‘hubs’.
  • The ACNC Register says that they operate in eight countries overseas. For only three of them is there information on the website.

Do they pay their directors?

  • There is insufficient public information to say.

Do they share the Gospel[2]?

  • Yes

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?

  • All the expenses may include some administration, so there is no clear way to even estimate the figure as defined above.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

Where were your (net) donations sent?

  • Although the AIS 2017 reports that no grants or donations were made, there is an $8K ‘Giving and donation expense’. The destination of this money is not disclosed.

Is their reporting up-to-date?

  • Yes (seven months after their year-end, on the last day allowed, and about the same time as the previous two years).
    • 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 11 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • ‘Donations and bequests includes ‘Grants’ and ‘Other Income’, yet zero is shown for ‘Grants and donations…’
    • The description of activities is the same as for the previous two years.
    • Praxeis says that it does not intend to fundraise, then lists four states where it is going to do it.
    • ‘Online’ is missing as a place where they are going to fundraise.
    • There is an item ‘Giving and donation expense’ in the Financial Report The financial statements are not an ‘Annual Report’ as that term is meant by the ACNC.
    • 2017, yet nothing is reported for ‘Grants and donations made…’
    • Outcomes are not reported.
  • Financial Report 2017: No, a true and fair view is not shown[3].
    • Like last year,
      • The directors’ belief that ‘there are no users who are dependent of its general purpose financial statements’, that is, that all its users, present and prospective can ask for a report tailored to their needs, is not plausible. This is a charity with 35 staff, a turnover a little less than a million dollars, and operating in seven states and eight overseas countries.
      • Some of the figures in the 2016 column, without explanation, are not the same as they were when reported in last year’s Financial Report.
      • The relationship between Praxeis and Crossway is more than landlord and tenant, yet that’s all that is disclosed.
      • ‘Employee benefits’, ‘including wages and salaries’ are (correctly) classified as a liability, yet ‘staff support donations made to ministry staff from which salaries have not been paid at year end’ are classified as a contingent liability. Are not liabilities therefore understated by $219K?
      • Using only three lines to classify the $1.92 m of cash flows is insufficient disclosure.
      • The second largest expense (after ‘Employee benefits expense’) is the unexplained ‘Ministry expense’ (the entire charity is a ‘ministry’).
      • There are other things that support my disagreement with the directors that a true and fair view is shown[4].

What was the financial situation shown by that Report?

  • The surplus as a percentage of revenue declined sharply from 8% to negative 1%.
    • ‘Employee benefits’ increased 8% and ‘Ministry expense’ (whatever that is) increased 56% (or 71% if last year’s figures are used).
  • Note 1 (i) reports that some of the cash given to ‘ministry staff’ may not have made it into the company’s bank account.
  • Gifts and donation expense is <1% of revenue.
  • The combination of term deposits and ‘Cash and cash equivalents’ represents eight months of revenue (the same as last year).

What did the auditor say about the last financial statements?

  • The auditor, Peter Shields, of Saward Dawson, Chartered Accountants, issued a ‘clean’ opinion.
  • Before deciding how much comfort to take from this
    • Read here and here to draw the right conclusions from such an opinion.
    • Re-read the ‘Financial Report 2017’ section above.
  • The potential understatement of revenue (see Financial Report 2017, above), was again thought by the auditor to be ‘of such importance that it is fundamental to users’ understanding of the financial report’ [AAS 706, paragraph 6, www.auasb.gov.au], as to warrant a separate paragraph in his report (‘Completeness of Income’).

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

  • No
    • ‘Who the Charity Benefits’ is blank.
    • The financial statements are not an ‘Annual Report’ as that term is meant by the ACNC.
    • ‘Phone’ and ‘Website’ are blank (but neither is compulsory).

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

  • The ‘Give’ page implies that there are different purposes and different ‘workers’ that you can give to, but these are not listed anywhere on the website.

Who are the people controlling the organisation?

  • Not shown on the website, but from the ACNC Register:
  • There has been no change since the last review.
  • Dale Stephenson is also a director of Crossway (and the other two Crossway charities).
  • David Lawton is also a director of Aussies Responding to Kids (ARK) Limited.
  • Unless Hiew Chang, the Secretary, is a member of the board, he should not be included on the Register.
  • There are 10 directorships in the name ‘James Hall’. 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 Praxeis’ James Hall 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.
  • The directors are answerable to the members of the company. But if the number of members is similar to last year (the Directors’ Report has been omitted this year), and with directors required to be members (the constitution), there is no accountability via the membership.

To whom is Praxeis accountable?

  • On most of the main menu pages, for instance here, these two logos are shown:

  • As a charity, Praxeis is accountable to the ACNC.
    • The ACNC’s ‘Charity Tick’, above, is used in support of you giving to them. And rightly so, because it would be unwise to give to a charity that is unregistered. The ‘tick’ also means Praxeis’ AIS is not overdue, and no compliance action has been take against it.
  • Praxeis is, as they claim above, also in support of you giving, a Member of Missions Interlink.
    • See the section Activities in this review for one opinion on the strength of this accountability.
  • As a company, Praxeis is still also accountable to ASIC for some things.

 

 

  1. Praxeis nominates Crossway as a ‘related party’, but says that the only relationship is the payment of ‘nominal rent amounts’ paid to Crossway [Note 12, Financial Report 2017]. Crossway does not consolidate Praxeis’ accounts with its own.
  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 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.
  4. ‘Other comprehensive income’ is missing from the Statement of Changes in Equity.   

There is no explanation for why the name of the audit firm is the most prominent name on the cover of a report that is both about Praxeis and belongs to Praxeis.

The expenses are a mixed classification.

For a charity with 20 employees (one more than last year), why is ‘Property, plant and equipment’ just $3K of computers? Is it because of cross-subsidisation by Crossway?

A Crossway director serves on the board of the charity from which Praxeis earned $23K in fees, Aussies Responding to Kids (ARK) Limited, yet it is not mentioned the under ‘Related Parties’.

Some employee benefits are shown under ‘Provisions – Employee Provisions’, some under ‘Other liabilities’.

Heart for Kids Australia Ltd: charity review

This is a charity review of Heart for Kids Australia Ltd (HFK), an organisation that is an Associate member of Missions Interlink and which has an online invitation to donate.

For the previous review, see here.

Are they responsive to feedback?

  • At the bottom of the ‘About’ and ‘Leadership’ pages (and therefore far from prominent on the website), there is an invitation to ask questions, give feedback, and make a complaint:
    • If you have any questions, feedback or complaint regarding our service or this website you may contact us via the contact form.
  • Accountability is not mentioned on the website. Transparency is though:

  • I sent them a draft of this review. They responded by email. Some changes have been made and a comment by them has been inserted as a result.

Is HFK registered?

  • Yes, as a charity.
  • HFK is a public company, a company limited by guarantee.
    • It does not have the provisions in its constitution to omit ‘Ltd/Limited’ at the end of its name.
    • Therefore, because it does not have Heart for Kids registered as a business name, it should be using its full name with the public. Not as on its website and Facebook.
  • There’s more to HFK than is disclosed on the ACNC Register.
    • First, another charity, Chinaheart International Incorporated (CI), shares two of the three directors of HFK, and an office. One controls the other, but which way it is doesn’t matter: CI’s web address on the ACNC Register leads to HFK’s website, and they write as if they were one organization; e.g. on that website they say

  • Here’s their explanation of the connection between the three charities:
    • Heart For Kids was born out of ChinaHeart International. When the work grew to serve children in other countries we felt a new umbrella orgainsation would serve the ministry better and give a clear direction as to who we are. The work previously done under the name of ChinaHeart and the ChinaHeart International Aid Fund is now done under the one name of Heart For Kids.
        • Why then are they reporting separately? (HFK has yet to take advantage of the ACNC’s group reporting concessions.)
  • HFK is also connected with a business, LST Group (a business name belonging to The Trustee for the David Ryan Trust).
  • HFK holds a fundraising licence in its home state. The absence of a licence in the other states that have a licensing regime for registered charities is only an issue if one or more of those states regard raising money online as ‘fundraising’.

What does HFK do?

  • See here.
  • Or the succinct version, from the Annual Information Statement (AIS) 2017:
    • Operating centres for fostering & training, leading volunteer teams to orphanages, scholarships help ensure children do not leave school due to financial causes.

Do they share the Gospel?

  • No

What impact are they having?

  • No information found.

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

  • This chart is under a heading ‘What reaches the children’:

  • It didn’t turn out this way this year: grants made were only 76% of the expenses.

Do they pay their directors?

  • This is not prohibited by the constitution.
  • There is insufficient financial disclosure to check.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • eWay and PayPal are used, so yes.

Where were the (net) donations sent?

  • The distribution of the grants between the three countries is shown here.
  • And within each country, here.
    • These two charts are not part of audited accounts, and are not for the financial year, but updated quarterly.

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

  • It’s a bit confusing, but it’s all on this page.
  • Which of the three charities is receiving the donation in each case is not disclosed.
    • Ministry comment: ‘We don’t receive gifts in the name of [CI].’
      • This is not what CI’s AIS 2017 says – it shows a figure for ‘Donations and bequests’.
      • CI Aid Fund also received ‘Donations and bequests’ in the 2017 year.
      • Both charities said ‘No’ to the question ‘Will the charity change or introduce any activities in the 2018 period’ in their AIS 2017, suggested that there was no intention of not continuing to receive donations and bequests.

Is their reporting up-to-date?

  • Yes (seven months after their year-end, a week before the deadline, the same time as last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017 (HFK only): Not quite
    • Why ‘Don’t Know’ for the NDIS questions?
    • Why no ‘online’ under fundraising?
  • Financial Report 2017 (HFK only): Yes
    • HFK is $12K under the threshold for reporting, and, despite the commitment to transparency (see above), chose not to submit a Report voluntarily.
    • 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.
    • Unfortunately for transparency, even if HFK start reporting as a group, so long as each of the charities remains ‘Small’, then a report still won’t be required.

What financial situation was shown in that Report?

  • NA
  • But from the AIS 2017 – remembering that this is a report for only one of the three charities –
    • $238K income, almost entirely from donations.
    • The one part-time employee cost $5K.
    • ‘Grants and donations made for use outside Australia’ totaled $115K.
    • The ‘bottom line’ was a surplus of $81K.

What did the auditor say about the last financial statements?

  • An audit should have been performed, but despite the commitment to transparency, there is no record of one on the website.

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

  • Yes

Who are the people controlling the organisation?

  • The ‘Leadership Team & Board’ is shown on the website, but it doesn’t definitely identify who is on the board[1].
  • From ‘Responsible Persons’ on the ACNC Register:

To whom is HFK accountable?

  • This graphic appears in the website footer:

  • HFK is an Associate member of Missions Interlink, an organization that has an accountability regime.
    • For one opinion on the strength of that accountability, see the section Activities in this review.
  • The other logo is the ACNC’s ‘charity tick’. HFK is accountable to the ACNC.
    • The tick means that HFK is registered as a charity, its AIS is not overdue, and the ACNC has not taken any compliance action against it.
      • But no more than this.
      • The accountability provided by the ACNC is generally at a high-level, and mostly not particularly timely.
  • As a company, HFK is still accountable for some things to ASIC.

 

 

  1. On the ‘leadership’ page on the website, HFK use, illegally, the Commonwealth Coat of Arms and the ACNC logo, to represent the governance of HFK.

Global Frontier Missions: charity review

This is a charity review of Global Frontier Missions (GFM), an organisation that is an Associate member of Missions Interlink, and, if the situation last year holds[1], solicits donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

You can read the previous review here.

Are they responsive to feedback?

  • The webpage for Australia was not available to check for feedback and complaint invitations, or comments on accountability and transparency.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is GFM registered?

  • Yes, as a charity.
  • An association, but not incorporated.
    • This means that GFM cannot enter contracts in its own name.
  • In its Annual Information Statement (AIS) 2017, GFM says that it doesn’t intend to fundraise ‘in the next reporting period’. This explains the continued absence of a fundraising licence in New South Wales (per the ACNC Register, the only state in which GFM operates).

What does GFM do?

  • From ‘activities’ in the Annual Information Statement (AIS) 2017:
    • We run an internship in India once a year. This involves training to nationals. We take a maximum of 4 students to India where we teach nationals in church principles. We also travel to rural areas to learn from the locals and about the local work in the church.

Do they share the Gospel[2]?

  • It is not required by its constitution:
    • Training and Mobilising (sic) the church while meeting felt needs in the community to share the Good News of Jesus Christ.
  • There is insufficient information available to say whether they do.

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?

  • There is insufficient information available to say.

Do they pay their board members?

  • It is not prohibited by its constitution.
  • There is insufficient information available to say.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • The webpage was not available.

Where were the (net) donations sent?

  • NA – donations were spent on the one employee (AIS 2017) and ‘Other expenses/payments’, and not, and apart from $32 (not $32K), on ‘Grants and donations made for use outside Australia’ (AIS 2017).

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

  • The webpage was not available.

Is their reporting up-to-date?

  • Yes – but a month late, which made it eight months after their year-end.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Yes
  • Financial Report 2017: Yes
    • GFM didn’t, because of its small size, have to submit a Financial Report. And it chose not to submit one voluntarily.
    • But 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?

  • NA.
    • There is no requirement for an audit in the constitution.

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

  • No
    • There still no ‘Entity Subtype’.
    • Is there really only one ‘responsible person’?
    • ‘Phone’ is still blank (but is not compulsory).

Who are the people controlling the organisation?

  • The constitution requires a minimum of three members, but there’s only one on the ACNC Register:

To whom is GFM accountable?

  • As a charity, to the ACNC.
  • To Missions Interlink via its Associate membership.
    • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. The website linked from the Missions Interlink gave a ‘This page isn’t working’ message.
  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.

Youth With A Mission Sunshine Coast Inc: charity review

This is a charity review of Youth With A Mission Sunshine Coast Inc (YSC), an organisation that has an online donation facility, 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.

Are they responsive to feedback?

  • There is no invitation to give feedback, or to submit a complaint, on the website.
  • Neither accountability nor transparency are not mentioned on the website.
  • When sent a draft of this review, they…did not respond. (Last year, two and a half months after publication, John Faull, one of the Committee members, responded with “Looks good!  Thanks.”

Is YSC registered?

  • As a charity, yes[1].
  • YSC is a Queensland incorporated association (IA28315).
  • They hold one business name, 30 Days International, that they are not using, but are still trading under two names, YWAM Waves and YWAM Sunshine Coast, that are not registered.
  • YSC doesn’t actively seek donations on its website, and in the Annual Information Statement (AIS )2017 said that it didn’t plan to fundraise ‘in the next reporting period’, so this explains its lack of a fundraising licence in Queensland[2].

What do they do?

Do they share the Gospel?[3]

  • Yes, in the ‘Outreach’ component of their ‘DTS’, and in some of their ministries.

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?

  • Some of the expenses are unreadable, others barely so, so no reliable comment can be made.

Do they pay their directors?

  • Some of the expenses are unreadable, others barely so, so no reliable comment can be made.

Can you get a tax deduction?

  • No.

Is their online giving secure?

  • See the Security Policy at the bottom of the giving page.
    • There is a 2% charge.

Is their reporting up-to-date?

  • Yes. But because YSC has the wrong ‘Financial Year End’ on the ACNC Register (30 June instead of 30 April), the reports were lodged eight months after their year-end.)
  • If you are considering a large donation, I’d suggest you reconsider. If you still want to after that, I would ask for readable, compliant, and up-to-date financial information (the accounts are for a year end that is now over 12 months ago).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Like last year, no.
    • ‘Other names…’ is blank.
    • The wrong type of financial statements is specified.
    • No outcomes are reported.
    • The website is not, as they imply, the source of an annual report.
    • The association number is missing.
  • Financial Report 2017: Like last year, no.
    • Again, despite having been audited by a chartered accountant, Peter Rule,
      • Two financial statements are missing.
      • The two statements that are included are both incorrect.
      • There is no responsible persons’ declaration.
      • The auditor’s letter accompanying his report is included.
    • Many of the figures are too faint to be reliably read.
    • The absence of any Notes last year has been improved only marginally – now there is one small portion of a policy note.
    • A second letter that is normally private has been, without explanation, included in the Report.

What financial situation was shown by that Report?

  • Given the deficiencies of the Report, including the limited audit that was performed (see below), it would be unwise to rely on this Report as a description of the financial state of YSC.

What did the auditor say about the last financial statements?

  • Once again, the auditor, Peter Rule, chartered accountant, of Complete Business Strategies Pty Ltd, has issued a qualified opinion.
    • Read here to see what this means compared to a ‘clean’ opinion.
    • This is Peter’s explanation of his qualification:
      • As is common for organisations of this type, it is not practicable for the Association to maintain an effective system of internal controls over receipts and payments until their initial entry in the accounting records.’
        • This is a huge deficiency in YSC’s practices. What it means is that, for 100% of everything that was given to or earnt by YSC, and for 100% of everything that was spent by YSC, the organisation has no checks to ensure that its transactions were reflected in the accounting records.
      • Why is it not possible for YSC to implement the necessary internal controls?  Other charities can.
      • Why are the directors happy to let this continue?
    • With this size gap in the audit procedures, and the deficiencies described under ‘Financial Report 2017’ (see above), YSC got off lightly – a refusal to issue an opinion seems more appropriate.
    • Peter is only qualified to do this audit because of the ACNC’s transitional provisions for reporting by incorporated associations:  the Queensland regulator doesn’t require the audit of YSC to be performed by a registered company auditor.

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

  • ‘Other Name(s)’ is missing the two names they use and the business name.
  • The year end is still shown as 30 June when it should be 30 April.
  • The description for ‘Annual Report’ does not lead to an annual report.
  • ‘Phone’, ‘Email’, and ‘Website’ are blank (but are not compulsory).

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

  • None.

Who are the people controlling the organisation?

  • They are not shown on the website.
  • The ACNC Register (under ‘Responsible Persons’) says that there are three directors:
    • Patricia Hensser
    • Brian Hunsburger
    • Faull John-Daniel (should be the other way around?)
  • The constitution only requires three members for the committee.
  • The committee is accountable to the members of the association. The number of members is not publicly available.

To whom are YSC accountable?

  • As a charity, to the ACNC.
  • And to the regulator of Queensland incorporated associations.
  • Although they don’t mention it on the website, they are members of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. Sometimes the name they use is slightly different: Youth With A Mission (Sunshine Coast) Inc.
  2. None last year in the other states with a licensing regime, so I assume that this has not changed this year.
  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.

From Seed to Trees: charity review

This is a charity review of From Seed to Trees (FST), an organisation that gives information online on how to give to it and is an ‘Associate Organisation’ of Missions Interlink.

For the previous review, see here.

Is it responsive to feedback?

  • There is no invitation on the website to give feedback or to make a complaint. Nor is there any mention of accountability.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is FST registered?

  • As a charity, yes.
    • But the ‘Ltd’ at the end has been accidentally omitted.
  • FST is a public company, a company limited by guarantee.
    • Not, as it says in the Annual Information Statement (AIS) 2017, an incorporated association.
    • It does not appear to have the provisions in its constitution necessary for it to omit ‘Ltd/Limited’ from the end of its name. So, as it does not have From Seed to Trees (or any other name) registered, the use of this name publicly (as on the website) is questionable.
  • FST said, in the AIS 2017, that it planned to fundraise in Queensland. It still doesn’t have a licence there (it is not exempt)[1].

What does FST do?

  • There’s a little here, but better is the 2017 ‘May FSST Newsletter’ (assuming this is still the current range of activities).
  • It is not clear how where what is reporting in the AIS 2017 fits in:
    • developing the principles of good leadership. Training of others as leaders. Giving education in religious development, and
    • We are involved with young leaders who help other students who come from other countries. The leadership develops good relationships (sic) and are able to help with their studies.
  • They invite people to go on ‘mission’ trips.
  • And perhaps the planned changes mentioned in the AIS 2017 have come to pass:
    • Changes planned One of the great (sic) needs to be addressed is bribery. How it effects the country financially but also has a big impact on the way people live. This is a difficult issue and we are still learning.
  • The ACNC Register says that FST operates in Belarus, Moldova (Republic), and Romania.

Do they 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?

  • ‘Other expenses/payments’ were 41% of the total (up from 28%). (The other 59% was for ‘Grants…outside Australia’.) The dollar figures are very small though.

Do they pay their directors?

  • There is no prohibition in the constitution.
  • But no financial information has been published to check for a payment.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA – online giving is not offered.

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

  • None shown on the website.

Where were the (net) donations sent?

  • No financial statements have been published.

Is their reporting up-to-date?

  • Yes (seven months after year end, a week before the deadline and the same time as last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Not quite – FST is not an incorporated association.
  • Financial Report 2017: Yes
    • Although FST didn’t, because of its small size, have to submit a Financial Report, 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?

  • The equity appears to consist entirely of the $2K surplus.

What did the auditor say about the last financial statements?

  • If an audit was performed the result has not been made public.

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

  • Not quite – there’s still a message ‘Charity to select subtype’.
  • ‘Phone’ and ‘Website’ are blank (but neither are compulsory).
    • There’s a phone number, another email address (and a postal address), here.

Who are the people controlling the organisation?

  • Not shown on the website, but
  • Shown under ‘Responsible Persons’ on the ACNC Register:

To whom is FST accountable?

  • As a charity, to the ACNC.
  • And, as a company, still for some things to ASIC.
  • To Missions Interlink, because it’s an Associate member.

 

 

  1. It is possible that one of more of the other states that have a licensing regime for registered charities would hold that FST’s online encouragement to the public to donate would mean that a licence was required.
  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.

Emmanuel Relief & Rehabilitation International: charity review

This is a 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?

  • There is no website, so no invitation to give feedback or submit a complaint. And nothing about accountability.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is ERR registered?

  • As a charity, yes.
  • Even though it says, in the Annual Information Statement (AIS) 2017, that it is incorporated, 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, as an unincorporated body with the ‘Entity Subtype’ ‘Advancing Religion’, is likely to qualify as a Basic Religious Charity.
  • It does not hold any business names.
  • ERR operates, per the ACNC Register, only in Western Australia. It doesn’t have a fundraising licence there. It says, in the AIS 2017, that it intends to fundraise, so if its donations come from the public it needs a licence.

What do they do?

  • The only information – there is no website and no Financial Report – is in the AIS 2017:
    • Funds were distributed for education, training, health care, disaster rehabilitation, rural community development projects and religious teaching. At meetings in Australia we raised awareness of the situation of people in need, and prayed for them.
      • This was with an income of $35K.
  • Part of the ‘EI Network’.
  • They operate overseas, per the ACNC Register, in three countries. With $34k of the $35K income being spent on overseas grants, this is most likely where they sent money, not people.

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 98% of the expenses.
    • We don’t know how much administration was deducted by the recipient though.

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 three countries shown on the ACNC Register (Canada, Philippines, and Uganda). The destination within the countries is 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, a week before the deadline).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Not quite
    • ‘Other names…’: One is a trading name (and they are now of little consequence), and the other is neither a trading name nor a business name. Two other trading names are not shown.
    • No outcomes reported.
  • Financial Report 2017: 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 also required by the constitution.

What financial situation was shown in that Report?

  • No Report (see above), but from the AIS 2017:
    • Donations returned to 100% of income (71% last year).
    • No employees.
    • ERR reported that its accounting method was ‘Cash’, a method that doesn’t generate assets and liabilities. Other than cash then, these came from outside the double entry system.
    • 98% of the payments were for ‘Grants and donations…’, all of it to overseas.

What did the auditor say about the last financial statements?

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

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

  • Not quite – ‘Who the Charity Benefits’ is blank.
    • It may be known by the names Emmanuel International, and Emmanuel International Australia, but these are not registered business names. It must therefore trade under its full name.
    • ‘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 another email address: australia@e-i.org/. And the phone number: (08) 9386 8488.

Who are the people controlling the organisation?

  • As shown on the ACNC Register (under ‘Responsible Persons’), the same people as last year:
    • Allison Chapple
      • Is Allison this one?
    • Heather Ellis
      • Shouldn’t it be ‘Margaret Ellis’?
    • Mary Roskams
    • Babu Simon

To whom is ERR accountable?

 

 

  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.

AccessTruth Limited: charity review

This is a charity review of AccessTruth Limited (AT), an organisation that seeks donations online, and is an ‘Associate Organisation’ 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?

  • There is no invitation on the website to give feedback or to make a complaint. Nor is there any mention of accountability.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is AT registered?

  • Yes, as a charity.
    • Three of the directors are also three of the four directors of the charity Crossview Australia Limited. It looks like AT is a subsidiary – but Crossview doesn’t mention this in its Financial Report.
  • AT is a public company, a company limited by guarantee[1].
  • It holds the business name AccessTruth, allowing it to omit ‘Limited/Ltd’ at the end of its name.
  • They are well over the threshold for GST registration, yet are still not registered.
  • AT operates, per the ACNC Register, only in New South Wales. It said in the AIS 2017 that they did not intend to fundraise, so that would explain the lack of a licence.
    • But it has an internet invitation to give. The absence of fundraising licences in the other states that have a licensing regime relevant to registered charities no doubt means that AT doesn’t equate this invitation with ‘fundraising’. One or more of those states may disagree.

What does AT do?

  • See here.
  • AT does not operate overseas [ACNC Register].

Do they share the Gospel?

  • No

What impact are they having?

  • No information found.

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

  • No financial statement is available. So, it is not possible to make this calculation.
  • On the giving page, they say that none of their donation receipts or sales revenue goes to what would normally be called administration:

Do they pay their directors?

  • It is allowed, but there is no information available to check.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned.

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

  • None

Where were your (net) donations sent?

  • ‘Grants and donations…’, both in and outside Australia, were zero.

Is their reporting up-to-date?

  • Yes, but only because they are still recorded as a ‘Small’ charity. Did they get approval to keep that size?

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • It is AccessTruth, not Access Truth.’
    • Why is ‘Online’ not selected under fundraising?
    • Plus, a couple of questions:
      • Does AT have permission to stay a ‘Small’ charity?
      • Does people overseas buying things on a website equal ‘Transferring funds or goods overseas’?
  • Financial Report 2017: Yes, but does AT have the ACNC’s permission to stay at ‘Small’? If not, then a Financial Report was required.
    • Whatever they do with the ACNC, 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 was required. Missions Interlink requires one though, so just ask.

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

  • Not quite – the business name is misspelt.
  • ‘Email’ and ‘Phone’ are blank (but the ACNC says that these are not compulsory).

Who are the people controlling the organisation?

  • Not shown on the website, but here are the people shown as ‘Responsible Persons’ on the ACNC Register:
  • The number of members is not disclosed, so we can’t assess the accountability coming from that quarter.

To whom is AT accountable?

  • As a charity, to the ACNC.
  • And, still for some things, as a company, to ASIC.
  • Three of the directors are also three of the four directors of the charity Crossview Australia Limited. It looks like AT is a subsidiary, But AT only says that Crossview is a ‘training partner’, and Crossview doesn’t address the question in its accounts.
  • Not mentioned on the website, but AT is accountable to Missions Interlink via its ‘Associate Organisation’ membership.
    • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. The previous incarnation, an unincorporated charity, was ‘Voluntarily Revoked’.

WorldShare: charity review

This is a charity review of WorldShare, 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?

  • Neither feedback nor complaints (other than those about your privacy) are invited on the website.
  • The ‘Accountability’ page on the website does not mention feedback, complaints, or any external accountability organisations.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is WorldShare registered?

  • As a charity, yes.
  • WorldShare is a public company (a company limited by guarantee).
    • It is permitted to omit ‘Limited/Ltd’ at the end of its name.
  • It holds one business name, CNEC Partners International.
  • WorldShare operates, per the ACNC Register, in all eight states.
    • It says – in the AIS 2017 – that it has a fundraising licence in every state with a licensing regime. Confirmed for New South Wales, South Australia, Victoria and Western Australian[1].

What do they do?

  • This description, from the Financial Report 2017, is probably the clearest:

  • Here what they reported for 2017 in the AIS 2017:
    • In the last financial year, WorldShare supported 11 direct partnerships. Through these partnerships, 1042 children were sponsored, with 1194 others educated outside of our child sponsorship programs. 460 individuals received vocational training and 4349 patients were provided with healthcare. Thousands of people were reached through spiritual ministries. To connect people in Australia with the work overseas, WorldShare hosted an international visit from a partner in Uganda, during which over 1900 people connected with that partner. Over 1500 people in Australia provided support for our programs in the year, including through child sponsorship. In the last financial year, $1.7M in expenses were used for the purpose of supporting our overseas partner organisations, while $388,000 was used for fundraising purposes to ensure WorldShare can continue to assist more people and communities around the world.
  • WorldShare says, on the ACNC Register, that it operates in nine countries. This is two more than the number stated in the Annual Report.

Do they share the Gospel[2]?

  • From ‘What do they do?’ (immediately above), and the Annual Report, it appears not.
    • Evangelism is probably even less likely now that they have tax-deductible status not just for their fund, but also in their own right.
    • The objects in the old constitution required it:
      • The Company is a religious institution whose values require the promotion of the Lord Jesus Christ to peoples throughout the world and their evangelisation on the basis of the principles of the Christian faith.
    • But the not so the new constitution:
      • (a) to love like Jesus and provide holistic benevolent relief to poor and marginalised persons and communities through relief or development projects…
    • Perhaps this is why, again this year, their fund, Christian Nationals Developing Countries Aid Fund, is nowhere mentioned.
      • The only place ‘Christian’ is mentioned in the Annual Report is in the name of an overseas partner.

What impact are they having?

  • This is WorldShare’s answer to the FAQ ‘How do I know that the project I support is effective?’

  • No evaluations were found. Nor anything systematic on impact.
  • WorldShare do not describe how what they do produces the changes that they are seeking in the beneficiaries. ‘Theory of change’ is not mentioned on the website.
  • Hopefully, with an ‘Evaluation Specialist’ on the board since May 2017, there will be at least some comment next year.

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

  • If we define ‘direct’ as the money that leaves Australia for projects – and this ignores the fact that some of this money may be used on local administration – ‘administration’ is 43% of expenses (up from 42%).
  • With getting a result for you costing this much, it would be reasonable for you to ask whether it would be more efficient to donate direct to the partner.  As three people and one organization from Australia did in the year ended 2017 to the Indian partner.

Do they pay their directors?

  • This is not allowed by their constitution.
  • The disclosure of expenses is insufficient to confirm that no fees were paid.

Can you get a tax deduction?

  • Since 13 May 2017, yes.
  • And since many years earlier, to its fund, Christian Nationals Developing Countries Aid Fund.

Is their online giving secure?

  • Security is still not mentioned.

Where were your (net) donations sent?

  • The only information in the Financial Report is that $1.34 m was sent overseas.
  • The Annual Report discloses the name of WorldShare’s 11 (down from 12 last year) overseas ‘partners’ and their country.
    • Unlike last year, though, the amounts sent to each country is not shown.
  • This is WorldShare’s answer to their FAQ ‘Where does my money go?’
    • Approximately 78% of funds raised go to partner programs that directly benefit vulnerable children and their communities. This includes the provision expertise (sic) to ensure that the funds are providing maximum benefits to their intended beneficiaries.
      • Note that this includes $375K of ‘Project costs’, that is, not money that goes to the beneficiaries. Without that spending, the percentage drops to 60%.

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

  • Many.
    • Why, when WorldShare has DGR status, are some things that you can give for ‘non tax deductible’ (sic)?

Is their reporting up-to-date?

  • Worldshare (Group not yet started): Yes (two days before the deadline, seven months after their year-end, and three weeks later than last year).
  • The Group: None due – Group began 1 July 2017.
  • The Trust: None due – Group reporting.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017[3]: No
    • Most of the figures in the ‘Comprehensive Income Statement summary’ are incorrect.
    • No outcomes are reported.
    • CNEC Partners International is not their former name.
    • Online’ has been omitted as a fundraising source.
  • Financial Report 2017[4]: No
    • Once again[5]
      • There is no reserve for the ‘Fair value adjustment of financial assets’.
      • The disclosure in the Statement of Cash Flows does not comply with the Accounting Standards.
      • The deficit used in the ‘Reconciliation of net cash flows from/(used in) operating activities to operating (loss)’ is different from the deficit reported in the Statement of Income and Comprehensive Income (sic).
      • The revenue disclosure in Note 2 does not match what is disclosed in the Statement of Income and Comprehensive Income (sic).
      • Why is ‘Staff Entitlement Provisions Movement’ not included in ‘Employee Benefits Expense’?
      • What is the difference between ‘Employee benefit accounts’ and ‘Employee Entitlement Provisions’?
    • The prior year figures in the Statement of Cash Flows do not match those in last year’s accounts.
    • ‘Increase (decrease) in GST Payable/Recoverable’ is not a cash flow.
    • The disclosure in the Statement of Changes in Equity and Accumulated Funds and Reserves does not comply with the Accounting Standards[6].

What financial situation was shown in that Report?

  • Last year’s return as a percentage of revenue was increased from negative 6% to negative 4%.
  • Both short- and long-term financial structure are sound.

What did the auditor say about the last financial statements?

  • The auditor, Lawrence R Green, FCA, of Shedden and Green Partners, issued a ‘clean’ opinion on the financial statements. I suggest you read the ‘Financial Report 2017’ section above before you decide how much comfort to take from this opinion. (And here and here to understand what ‘clean’ means.)

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

  • Worldshare: Not quite – the information under ‘Other Name(s)’ is still incorrect.
  • The Group: No. Four fields are blank.
  • The Trust: No.
    • ‘Other Name(s)’ is incorrect.
    • ‘Email’ and ‘Website’ are blank (said by the ACNC not to be compulsory).

Who are the people controlling the organisation?

  • The people introduced here.
  • With a couple of name variations, this is the same as those shown on the ACNC Register (under ‘Responsible Persons’):
    • Joanne Armstrong
      • Is it this Jo Armstrong?
    • Stuart Harris
    • Krystal Leanne John
    • John Lamerton
    • Peter Leau
    • Victoria Lee
    • Alexandra Elizabeth Rodgers
    • Craig Murray Wilson
  • At year-end, there were only 18 members [Financial Report 2017]. As directors must be members, there’s not much effective accountability to the membership (but more than last year with only 13 members).

To whom is WorldShare accountable?

  • As a charity, to the ACNC.
  • And, still for some things as a company, to ASIC.
  • Not mentioned on the website, but WorldShare is a member of Missions Interlink.
    • For one opinion of the strength of that accountability, see the section Activities in this review.

 

 

  1. Search facility temporarily unavailable for Tasmania and Queensland.
  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. A Group AIS was not required.
  4. A Group Financial Report was not required.
    • The breakup of donations is not shown (it is in the Annual Report).
    • Reading the market price of available-for-sale investments is not a ‘critical…judgement’.
    • Nowhere is the tax-deductible fund, Christian Nationals Developing Countries Fund, mentioned.
    • The title Statement of Income and Comprehensive Income doesn’t make sense.In addition:
  5. In addition:
    • The title of that statement doesn’t make sense.
    • The revenue recognition practice does not match the policy Note.
    • Confusion is caused by the inclusion of cents in the first four of the revenue items in the Statement of Income and Comprehensive Income.