Northpointe Baptist Church Incorporated: charity review

This is a charity review of Northpointe Baptist Church Incorporated (NBC), an organisation that has a public invitation to give. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Conflict of interest

I am an active participant in the community that, many years ago, chose to incorporate as NBC.  However, neither myself nor my wife are, nor do we intend to become, members of the legal entity. Some conflict of interest remains though, so I have been careful to review this charity in the same way as I have reviewed every other charity.

Is it responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • Accountability is not mentioned on the website.
  • I sent them a draft of this review. Here is their response:
    • Thanks for performing a charity review of Northpointe.  It is extremely useful to have, and we will use it to guide is through making necessary changes to the way things are administered, recorded and reported.  The church strives to be transparent and accountable in everything that is done.
    • They also gave some feedback. This has been included below the applicable comment.

Is it registered?

  • Yes, as a charity.
  • NBC is an Australian Capital Territory (ACT) incorporated association (A 04911).
  • It operates, per the ACNC Register, in Australia only in that territory.
  • It holds no business names. It therefore should to ‘trade’ only under its full name. Not like it does on its website and on Facebook.
  • The ACNC Register says that it operates overseas only in Vietnam. But the website says otherwise:

  •  Ministry comment: ‘Regarding operating overseas, we do support missionaries overseas, but this was not included in last years (sic) report as we didn’t visit or engage in any “operational” support during the year.  Vietnam was outlined as a mission trip there (sic) was organised during the year.’
    • Reviewer response: Providing funds is an activity for ACNC purposes.
  • It has no fundraising licences. Whether or not it requires one in a state that has a licensing regime applicable to charities, depends on whether that state believes that an internet invitation to give qualifies as ‘fundraising’.

What does NBC do?

  • The usual local church things: see ‘Missions’, ‘Ministries’, and ‘Our Message’ under ‘About’, all on the home page.

Do they share the Gospel[1]?

  • 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 expenditure is not classified to allow an estimate of this figure.

Do they pay their board members?

  • There is nothing to prohibit this in the constitution.
  • The financial disclosure doesn’t allow a check for such payments.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • It is not until the fourth page of the process that security is mentioned. And then in small print.
    • Stripe is used, so your payment should be secure.

Where were the (net) donations sent?

  • For only $12K of the $41K is this disclosed: ‘Manna (Vietnam Orphanage)’.
    • How does this relate to ‘GVI’ (above) and here?

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

  • ‘General Funds’
  • ‘Missions’
  • ‘GVI’
  • ‘Building Fund’

Is their reporting up-to-date?

  • Yes (four and a half months after their year-end, three weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2017: No
    • The ‘Description of charity’s activities and outcomes’
      • is not about 2017 particularly, and
      • has no outcomes.
    • The ‘Accounting method…’ does not match the one that has been used.
    • ‘Donations and bequests’ does not match the figure in the Profit & Loss Statement.
    • There are again no figures under ‘Balance Sheet Extract’.
  • Financial Report 2017: Yes
    • But only because it has been voluntarily submitted to the ACNC, and voluntarily submitted reports do not need to comply with the ACNC legislation.
      • NBC’s doesn’t comply because it deviates materially from what is required by the accounting profession.
        • For instance, there are no Notes to the accounts or Directors’ Declaration, and there is significant confusion over the reporting framework.
    • The reviewer has also deviated materially from the requirements of his profession.
    • Ministry comment: ‘The committee will work to better understand and improve accounting practices’.

What financial situation was shown in that Report?

  • 44% of the expenditure went on the one full-time employee (Annual Information Statement (AIS)2017).
  • The next highest expenditure was ‘Missions’ plus ‘Love Offering’, 28%.
    • Much more than this could have been given – NBC again has a substantial sum in the bank ($149K).
      • No explanation is given for holding such a large sum.
  • The only other figure greater than $5K was ‘Music Ministry’, $17K (11%).
    • This seems a disproportionately large amount.

What did the auditor say about the last financial statements?

  • The auditor, Doug Burgess, Chartered Accountant, of BLM Accounting Services, concluded that
    • Based on our review, which is not an audit, 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 Church’s financial position as at 30th June 2017 and of its financial performance for the year ended on that date in accordance with the Australian Accounting Standards as noted in note 1 (sic).
      • There is no ‘note 1’.
      • If not an audit why this stamp on the financial statements?

      • Under ‘Scope of Review’ he says that ‘With the exception of trade creditors the statements have been prepared on a cash bais (sic)’. This basis is not one that is recognised by the Standard-setters, and there is therefore no way that the statements ‘present fairly’ as he claims.
    • This review falls so far short of the accounting profession’s requirements for a review that it is difficult to have any confidence in his opinion.

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

  • No:
    • A PO Box number is not a ‘street address’.
    • The constitution contains neither of the two clauses necessary to make NBC a not-for-profit.
    • ‘Phone’ and ‘Website’ are missing (but the ACNC says that neither are compulsory.

Who are the people controlling the organisation?

  • Per the website:

  • Which listing has little correspondence with what is shown on the ACNC Register (under ‘Responsible Persons’):
  • Ministry comments: (1) ‘The committee is looking to have the web site better maintained and will aim have any needed changes incorporated. (2) There have been changes to the leadership team over the past few months and the web site update was missed.  Thanks for outlining that.

To whom is NBC accountable?

  • As a charity, to the ACNC.
  • And to the ACT regulator of incorporated associations.

 

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

Cosmos Healthcare Inc: charity review

This is a charity review of Cosmos Healthcare Inc (CH) 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.

Is it responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • Their values include accountability, openness and transparency:

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

Is CH registered?

  • As a charity, yes.
  • CH is a WA incorporated association (No. A1010684A).
  • It holds no business names yet trades under the name Cosmos Healthcare.
  • CH operates, per the ACNC Register, only in Western Australia. It has a fundraising licence there. But nowhere else.
    • Whether it needs one in the other five states that have a licensing regime for charities depends on whether those states think that inviting donations via the internet is ‘fundraising’.

What do they do?

  • They describe themselves as, ‘an intercontinental healthcare organisation’, and ‘an international health and development organisation’. Read more here.
    • The ACNC Register confirms that they operate overseas only in Zimbabwe.
  • Here’s their ‘Description of charity’s activities and outcomes’ in the AIS 2017:
    • The organization supports financially a medical centre in Zimbabwe. We also send medical teams to assist local medical staff, for treatment of local people and to train local people.
  • More balanced, and detailed, is the description on GiveNow:

Do they share the Gospel[1]?

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

What impact are they having?

  • Nothing 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.
    • For instance, outside ‘Donations’, what portion, if any, of the other expenses were direct to healthcare delivery in Zimbabwe?
    • There is a figure ‘Administration’ ($12K), but other administrative expenses, like ‘Property’ and ‘Insurance’ are separate items.

Do they pay their directors?

  • There is nothing to prohibit this in the constitution.
  • The financial disclosure doesn’t allow a check for such payments.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

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

Where were the (net) donations sent?

  • There is no information in the Financial Report.
  • Presumably, from information on the website, the money is sent to this organization.
    • Despite one of their four values being ‘Accountability’, neither ‘financial statement’ nor ‘audit’ is mentioned on their website.

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

  • ‘Extended Care Patients’
    • There is a list of these patients on the second page under ‘Credit Card’.
  • ‘Medicine Supply Campaign’
  • ‘General Donations – 2017/18’

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Cosmos Healthcare is not disclosed as an ‘other name’.
    • The ‘Description of charity’s activities and outcomes’ is not particularly about 2017.
    • No outcomes are reported
    • The state in which they intend to fundraise in 2018 is not shown.
  • Financial Report 2017[2]: No
    • The directors have decided to produce special purpose financial statements, the type of statements that do not have to comply with all the Accounting Standards. Given that this type is only appropriate when the users, both current and prospective, do not need a regulator to help them get the financial information they need, this decision is questionable.
      • The directors do not say why they think that “the association is not a reporting entity” (and is thus qualified to produce the lower standard statements).
    • The Statement by the Committee of Management does not comply with the ACNC’s requirements.
    • Several of the usual Notes are missing.

What financial situation was shown in that Report?

  • The deficit as a percentage of revenue was increased from 1% to 2%.
  • Relatively low liabilities (all current) means that both short- and long-term financial structure are sound.

What did the auditor say about the last financial statements?

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

  • Not quite – the name they use, Cosmos Healthcare, is missing.
  • Both the website and Facebook still have a different phone number: (08) 6168 1670.
  • It is unwise to use a personal email address as a ‘Charity Address for Service’.

Who are the people controlling the organisation?

  • Those listed here on the website.
  • Which is quite different from the list (under ‘Responsible Persons’) on the ACNC Register:

To whom is CH accountable?

  • As a charity, to the ACNC.
    • CH shows the ACNC’s ‘charity tick’ in its website header.
      • Apart from saying that CH is registered with them, the ‘tick’ also means that CH’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • Not mentioned on the website, but they are a member of Missions Interlink.
    • For one opinion of the strength of this accountability, see the section Activities in this review.
  • CH is also accountable to the Western Australian regulator of associations.

 

 

  1. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  2. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports.  To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.

EA Insurance: charity review

This is a charity review of EA Insurance (EAI), an Associate member of Missions Interlink, ‘the Australian network for global mission’.

For last year’s review, see here.

Is EAI responsive to feedback?

  • In its ‘Complaints and Disputes Policy’, EAI says that it values feedback.
  • On its website, it talks about the accountability of others, but not of itself.
  • I sent them a draft of this review. Like last year, they did not respond.

Is EAI registered?

  • Not as an entity in its own right.
  • To receive charity tax concessions from the Australian Taxation Office (ATO), a charity must register with the ACNC. The company behind the EAI name (see below) appears to satisfy the requirements for registration, yet neither the company nor its owner (see below) say why it has not registered.
  • EA Insurance is a business name belonging to EA Insurance Services Pty Ltd (the company):

  • The company’s website uses one of the names above, EA Insurance Services.
  • The company is a not-for-profit, one that is wholly-owned by a charity, EA Foundation:

    • In the accounts of the charity, the company is, without explanation, referred to as EA Insurance Project Trust. This entity does not have an ABN.
    • The company is a proprietary company, one limited by shares rather than by guarantee.
    • As a ‘small proprietary company’, it only has to lodge financial reports in limited circumstances.
      • 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.”
      • Although you will not be donating to them, by insuring with them you are supporting their Christian cause, so are eligible to ask for this ‘financial statement.’

What does EAI do?

  • From the EAI website:
    • EA Insurance Services is a specialist provider of insurance and risk management services to Faith, Charity and Not for Profit organisations throughout Australia.
  • It describes itself as a ‘Christian organisation’.

Does EAI share the Gospel?[1]

  • It appears not.

What impact are they having?

  • No information on the website.
  • Nothing in the Financial Report of its owner.

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

  • No separate financial statements are published.

Do they pay their board members?

  • Neither constitution (without paying an ASIC broker) nor accounts are available to check.

Can you get a tax deduction?

  • NA – donations are not sought.

Is their online giving secure?

  • NA

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

  • NA

Where were your (net) donations sent?

  • NA

Is their reporting up-to-date?

  • Check with their regulator, ASIC.

Does their reporting comply with the regulator’s requirements?

  • Check with their regulator, ASIC.

What financial situation was shown in that Report?

  • No Report is publicly available.

What did the auditor say about the last financial statements?

  • No audit report is available.

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

  • NA

Who are the people controlling the organisation?

  • Not disclosed.

To whom is EAI accountable?

  • To Missions Interlink, because it’s an Associate member.
  • The company is accountable to ASIC.

 

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

Chinese Church Support Ministries Limited: charity review

This is a charity review of Chinese Church Support Ministries Limited (CCS), 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.)

You can read last year’s review here.

Is it responsive to feedback?

  • A ‘News from CCSM Australia’ post last year invited feedback from supporters.
  • There is no mention of accountability on the website that CCS shares.
  • I sent them a draft of this review. Like last year, they did not respond.

Is CCS registered?

  • As a charity, yes.
    • But still, over fourteen months after the last review, in its old name, Antioch Missions.
    • Not to be confused with the charity Antioch Missions International Inc.
  • CCS is a public company, a company limited by guarantee.
  • It has the provisions in its constitution to allow it to omit ‘Ltd/Limited’ at the end of its name, but has not registered as business names the other names it uses, CCSM or CCMS Australia
  • CCS operates, per the ACNC Register in New South Wales (NSW) and Western Australia (WA). Its registered office as a company is an address in WA (www.asic.gov.au,) so that explains the second state. But with an Australian Capital Territory (ACT) address for its ‘Charity Street Address’, why NSW?
  • Information in it its Annual Information Statement (AIS) 2017 shows that it believes that an internet invitation does not count as fundraising, so this probably explains, given its very small donations revenue, why it has no fundraising licences.

What do they do?

  • From the AIS 2017:
    • In Australia, every month we email prayer letters to supporters living in Australia, for purposes of educating those outside of China, about its needs. A major area where our donations are directed to is our Literature ministry which sees the printing of Bibles and Christian teaching material which is distributed throughout China. Organised teams for volunteers to go into China for short trips (2 weeks) to participate in Mercy Work projects, Prayer teams and Cross-Cultural-English Teaching ran throughout 2017 and will continue to do so in 2018. This is the main way that we get people outside of China into China to participate in supporting and serving China.

Does CCS share the Gospel?[1]

  • Presumably those who go on the ‘short trips’ (see above) share the Gospel if they get the opportunity.

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 AIS 2017 shows that it cost them $5K to send $16K (to China).

Do they pay their board members?

  • This is prohibited by the constitution.
  • There’s insufficient financial information disclosed to check for a payment.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned, but PayPal is used, so the giving should be secure.

Where were your (net) donations sent?

  • This is not disclosed.
    • $16K is shown for ‘Grants and donations made for use outside Australia’. China, per the ACNC Register is the only overseas country in which CCS operates.

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

  • No choice is given online.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Except for a change of the years mentioned, the ‘Description of charity’s activities and outcomes’ is identical to last year. Which means that it is not specific to 2017.
    • No outcomes are reported.
  • Financial Report 2017: Yes
    • Their size means that they are not required to lodge a Financial Report.
    • But their Associate membership of Missions Interlink requires them to “have available for [their] members and supporters a clear and appropriate financial statement (sic) which has been approved by its auditor.”
    • Assuming that they complied, they could have lodged this ‘financial statement’ voluntarily, but they chose not to.

What financial situation was shown in that Report?

  • The AIS 2017 only has to disclose totals for assets, liabilities and equity (net assets). For CCS they are $25K, $8K, and $17K.

What did the auditor say about the last financial statements?

  • There is nothing to indicate that an audit was performed.

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

  • No
    • Antioch Missions is not the ‘Legal Name’.
    • A postal address is still given instead of the street address.
    • Chinese Church Support Ministries is not an ‘other name’.
    • ‘Phone’ and ‘Website’ are still blank – but the ACNC says that they are not compulsory.

Who are the people controlling the organisation?

  • Not mentioned on the website.
  • From ‘Responsible Persons’ on the ACNC Register, the same three as last year:
    • Daniel Bao
    • Murray Cameron
    • Hercus Graham (the wrong way round?)
    • The constitution allows the company to have only three directors.

To whom is CCS accountable?

  • As a charity, to the ACNC.
  • CCS is an Associate member of Missions Interlink. Missions Interlink has an accountability regime.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • The constitution allows the company to have only three members, so if the three directors are members, there may be no accountability from the membership.

 

 

  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.

Asia Evangelistic Fellowship International Inc.: charity review

This is a charity review of Asia Evangelistic Fellowship International Inc. (AEFI), 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?

  • Neither feedback nor complaints are invited via the website.
  • I sent them a draft of this review. Unlike last year, they…did not respond.

Is AEFI registered?

  • As a charity, yes.
    • AEFI is controlled by an entity called the (AEFI) ‘International Council’. The membership is not disclosed.
  • AEFI is a Western Australian incorporated association (A1007002D).
  • It has registered, as a business name, the name it uses on the internet, AEF International.
  • Apart from its office in Western Australia, AEFI operates, per the ACNC Register, in New South Wales and Victoria. AEFI also has an invitation to give on the internet.
    • It still does not have the registration necessary, an ARBN, to operate interstate.
    • It still does explain why it has no fundraising licences.
  • There are two countries shown on the ACNC Register additional to those to which AEFI sent money in 2017: China and Malaysia.

What does AEFI do?

  • The website and the AIS 2017 give the wrong impression. They make no distinction between AEFI and the national AEF organisations:

  • AEFI is the coordinating body for ‘the autonomous chartered national organisations and donor bases known as Asia Evangelistic Fellowship and other organsations started by/or affiliated with AEFI’ [the constitution, paragraph 6],
  • There is no other Asia Evangelistic Fellowship entity with an ABN, so it appears that AEFI acts as both this coordinating body – the ‘international office’ – and the local AEF organization.
    • Otherwise, why would AEFI be soliciting donations?

Does AEFI share the Gospel?[1]

What impact are they having?

  • Nothing systematic found.

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

  • ‘Donations and bequests’ were $339K (AIS 2017). ‘Net costs’ (a list of donation destinations) totalled $251K. That’s 74% to ‘the field’. Nowhere near 90%.
    • Is the reconciliation in the definition of ‘designated’? In other words, donations to ‘General’ are excluded? But if that is the case, why assume that people who are giving to ‘General’ are not expecting their donation to go to ‘the field’? There is no explanation on the giving page that ‘General’ is for administration expenses. In fact, elsewhere, the opposite is implied:

    • Either way, the 90% claim is deceptive.
    • It would be reasonable to ask them why if would not be more efficient for you to send the money direct to the destination.

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?

  • The ABN record says no. But they accept donations for a third party:

  • GDG is a secular organisation.

Is AEFI online giving secure?

  • Despite saying in the review last year that they would put a statement about security, there still nothing said on the first page.

Where were your (net) donations sent?

  • For 92% of the money only a country is specified.
  • 70% goes to India (8% of the Indian total goes to an organization called ‘Destiny India’).
    • If we knew the state, we could search here to see if the money had been received.

Is their reporting up-to-date?

  • Yes (seven months after their year-end, two days before the (extended) deadline, and over a month 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 nine months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No.
    • The activities described are not just those of AEFI; they include AEF organisations overseas.
    • No outcomes are reported.
  • Financial Report 2017: No.
    • Totally inadequate, as it has been for each of the four years that Reports that have required by the ACNC.
    • This is despite saying last year that a review in 2017 would ensure ‘that its financial reporting meets the requirements of all regulators.’
    • The reporting is not only well short of what the ACNC requires and, on any reasonable definition of ‘appropriate’, non-compliant with Mission Interlink’s standards, but it is also non-compliant with its own requirements (its constitution).
    • More is missing from the Report than is included:
      • Two of the four required financial statements.
      • No Responsible Persons Declaration.
      • No Notes
    • And the two statements that are included do not comply with the Accounting Standards – including basic accounting.
      • ‘Gross profit’ is not (Donations + Book Sales) less money sent overseas.
      • The ‘Futures Fund’ is not a liability:

  • The auditor is not qualified to do the audit, and the audit that he has done does not comply with the Australian Auditing Standards.

What financial situation was shown by that Report?

  • Because of the condition of the Report, no comment.

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

  • The auditor (the third one in as many years), Peter Attwell of Attwell Partners, issued a ‘clean’ opinion. But given the state of the Financial Report (see above), I wouldn’t put much store in this.
    • Peter is not a registered company auditor (asic.gov.au) so is not qualified to do this audit.

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

  • Almost – a PO Box number is not a ‘Street Address’.
  • It is unwise to use a personal email address as the ‘Charity Address for Service.’

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

  • General’
  • ‘AEFI Futures Fund’
  • ‘Solid Rock Cambodia Hospital’
  • ‘Support the General work of AEFI’ – duplicating the first choice
  • ‘Support a Missionary Trainee’
  • ‘Support a Child
  • ‘Support a Community Project’
  • ‘Support a National Worker’
  • There is a brief description of these elsewhere on the website.
    • ‘Nepal Earthquake Appeal’ is no longer an option, and the information on ‘Solid Rock Cambodia Hospital’ is out-of-date.

Who are the people controlling AEFI?

  • This is the way it should be (from the constitution):

  • But this is how it is:

  • You can meet the incumbents of these three offices here.
  • Why no mention of the International Council?
  • The constitution goes on to say that the International Council appoints the International Director and the Board of Directors.
  • But the other members of the Board are not shown.
  • The ACNC Register (under ‘Responsible Persons’) says that the following people are on the AEFI Board:

To whom is AEFI accountable?

  • Despite saying in response to last year’s review that ‘We are happy to state on our website that we are a member of Missions Interlink and also accountable to ACNC’, ’accountability’ is still not mentioned. Nor is Missions Interlink (other than in the newsletter (see below).
  • AEFI is accountable to the ACNC.
  • And to the Western Australian regulator of incorporated associations.
  • In its newsletter it correctly claims to be an ‘accredited member’ of Missions Interlink:

    • Missions Interlink is an organisation that has standards with which AEFI must comply.
      • For one opinion on the strength of this 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.
  2. Last year I did not appreciate the distinction between AEFI and the national AEF organisations.

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.