The ACNC and the promotion of the charities it regulates, including the case of ‘Food Ladder’

The Australian Charities and Not-for-profits Commission (ACNC), the national regulator of charities, under ‘ACNC news’, has a series ‘Getting to Know’. Here it promotes particular charities. This is the introduction used: ‘With more than 56,000 charities in Australia, there are thousands of fantastic stories about the impact charities have on their local community.’

A regulator promoting those that it regulates didn’t sit right with me. Here, from the OECD publication, Governance of Regulators[1], is some support for my disquiet:

I asked the ACNC about their decision:

They said that they would be publishing the criteria but declined to respond to the bigger question publicly.

Leaving aside the wisdom of their practice in promoting charities, one would expect that one of the selection criteria would be that the charity is compliant with the regulator’s requirements.

‘Registered charity’ Food Ladder’ was recently promoted:

The ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”. #1 is ‘Check the charity’s name.’

A search on the name ‘Food Ladder’ on the ACNC Register of charities gives a surprising result – no results:

This is because, even though the ACNC says that the charity they were promoting, Fair Business, was ‘commonly known as Food Ladder’, Fair Business, without comment by the ACNC, has omitted to include the name ‘Food Ladder’ in the section ‘Also known as’.

A bigger issue with the name though, is that, again without comment by the ACNC, it is wrong on the ACNC Register. The legal name, the name required by the ACNC, is ‘Food Ladder’, not ‘Fair Business’. And it has been that way since December 2014:

This name is also meant to match that shown in Food Ladder’s governing document but the charity, again without comment by the ACNC, has not lodged one. (They have something under ‘Governing Document’, but this is their ‘Certificate of Registration on Change in Name[2].)

Other ‘Food Ladder’ entities

The name on the Register is also meant to match the name on ASIC’s register. A search on this shows that it does, but also reveals another current ‘Food Ladder’ company:

This company is mentioned only once on the website (here), and then only just its name. Yet it is a ‘wholly owned subsidiary’ (Financial Report 2017):

There’s also a ‘Food Ladder’ company in India. This company is not mentioned in the Financial Report.

Food Ladder does not say in the Financial Report whether it is reporting as an individual entity or a group, but it acknowledges that ‘Food Ladder International Pty Limited’ is a related entity[3].

So, all in all, neither Food Ladder nor the ACNC score well on ‘Name’, the first of the things that the ACNC suggest you check before giving.

Name aside, if you like the look at what Food Ladder is doing, let me know if you want a review on the ACNC’s other criteria.

  1.  From Chapter 5 of the OECD’s Governance of Regulators (https://www.oecd-ilibrary.org/governance/the-governance-of-regulators_9789264209015-en).
  2. This was lodged three years after the change.
  3. There is no comment on the fact that 62% of Food Ladder’s current assets is money owing by the subsidiary.

The Leprosy Mission Australia: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

The Leprosy Mission Australia’ (TLMA) is one such Member, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

TLMA did not respond to a draft of this review.

The charities’ regulator, the ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name.
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘The Leprosy Mission Australia’[3], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[4].

1.  A search on the ACNC Register of charities leads to a charity with that name.

2. NA

3. The “web address begins with ‘https’” and there is a “closed padlock symbol next to the web address in the address bar”, so the website is secure [the first ACNC article above]. On the page two of the giving process the logo of ‘SecurePay’ is shown, but there is no link to information on this security.

4. The Australian Business Register (linked from TLMA’s ACNC Register record), says that the charity is entitled to receive tax deductible gifts.

5. Contrary to what it says on the Register, in the AIS 2018, on the website, and in the Annual Report 2018, TLMA is not a charity that has projects itself, but is a ‘Supporting Country’, raising money in Australia and providing ‘expertise…to the projects’ they fund (Annual Report, page 30).

In 2018, they raised $5.44 million. From this they made overseas grants of $1.72 million (36% of expenses), and had ‘Employee expenses’ of $1.32 million (27%). They don’t comment on the effectiveness of this fundraising.

Although the note number has been omitted in the statement, Note 20 shows the distribution of the $1.72 million country by country. It is headed ‘Distribution to TLM Global Fellowship’, so presumably the recipient was the national ‘The Leprosy Mission’ organisation in each of those countries?

There is no information on how TLMA ensures that (a) their donations reach these organisations, (b) what happened to the donations after they reached those organisations, and (c) what TLMA does to ensure that your donations are used on the project you selected.

Impact

There is some information on a small portion of the work overseas in the reports of the two mid-term evaluations that were conducted in 2018. A link to the evaluations is not offered. There is no overall assessment of impact, either in 2018 or over the last few years.

________________________________________________________

For more a more in-depth review, please contact me.

  1. https://missionsinterlink.org.au/about/ 
  2. http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  3. See here for last year’s review.
  4. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?Would you like to spend your money, or time if volunteering, to support these objectives?Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

 

Every Home Global Concern Ltd: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

Every Home Global Concern Ltd ’ is one such Member, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

They did not respond to a draft of this review.

The ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘Every Home Global Concern Ltd’[3], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[4].

1.   A search on the ACNC Register of charities leads to a one in that name.

However, the website on the Register, www.globalconcern.com.au, leads to a website in the name ‘Global Concern’. This is not a registered business name.

The website that is linked from Missions Interlink is different again: www.everyhomeforchrist.org.au.

A search of the Register on the name ‘Every Home for Christ’, leads to the above charity. This is because the charity has recorded that name under ‘Also known as’.

The equation of the two can be seen on the home page of Every Home for Christ: the name in the header is ‘Every Home for Christ’, while in the footer the ACFID accreditation of the charity is described. But the description uses another two different names for the charity, ‘Every Home Global Concern Australia’, and ‘Every Home Global Concern’ , neither of which is registered:

And the second name reports its ABN as 28 004 778 081, an ABN that belongs to World Vision Australia.

The charity also operates a fund, gifts to which may be tax deductible: Every Home Global Concern Ltd Australia Overseas Fund. There is no mention of this fund on either website.

Confusing.

End of review.

_________________________________________________________

Contact me if this charity is still in the running for your donation, and you want the answers to the other questions. A lengthier review is also possible.

 

 

  1. https://missionsinterlink.org.au/about/http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  2. See here for last year’s review.
  3. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?Would you like to spend your money, or time if volunteering, to support these objectives?Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

 

GENESIS Counselling & Training Service Inc: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

GENESIS Counselling & Training Service Inc’ is one such Member, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

They did not respond to a draft of this review.

The charities’ regulator, the ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘GENESIS Counselling & Training Service Inc’’[3], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[4].

1. A search on the ACNC Register of charities leads to a charity with an almost identical name, Genesis Counselling And Training Inc.(Genesis) (emphasis mine).

2. NA

3. The “web address begins with ‘https’” but there is no “closed padlock symbol next to the web address in the address bar”, so the website is only partly secure [the first ACNC article above].

You cannot donate online so the question of the security of your credit card information is not relevant.

4. The Australian Business Register (linked from Genesis’ ACNC Register record), says that the charity is entitled to receive tax deductible gifts.

5.  For what they do, see the ‘Summary of activities’ on the Overview page on the Register. In 2018, here’s what they did overseas (from the AIS 2018):

“UGANDA – 4 Primary schools with 1,500 village children consistently achieving higher results than Government schools. Secondary School has 500 students. Teacher Training College currently 550 attending – all have employment before graduation. 75 Community Development Groups with 3000 members learning income generation to educate their children in our schools. All groups are eligible to apply for Annual Grants.

KENYA – 10 projects doing well with total beneficiaries of 3,500. All children are in school receiving a cooked meal every school day of the year. A feeding programme for 300 malnourished children has been commenced on Saturdays for remote Maasai children. In another Maasai area, a perimeter fence is being erected to protect children and school buildings from wild animals.

INDONESIA – Training facilities are have been upgraded for tertiary students and pre-school activities running smoothly. Renovations are completed at the Mental Health Facility,

For more detail, see the Annual Report on the Register.

Noting that the figure comes from a Financial Report that has significant issues, 76% of the resources consumed in 2018 are described as ‘Counselling & Training Support’. The note supporting this amount has the name and country of every recipient of this money. The largest amount is only 11% of the total, so the risk is dispersed.

There are no results, outcomes or impact reported on the ACNC Register or the website.

Genesis do not say anywhere how they ensure that your donations are used for the intended purpose. The Annual Report describes some visits by Genesis staff; in those places one can have some confidence on the use of the money.

________________________________________________________

For more a more in-depth review, please contact me.

 

 

  1. https://missionsinterlink.org.au/about/http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  2. See here for last year’s review.
  3. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?Would you like to spend your money, or time if volunteering, to support these objectives?

    Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

 

Care4Kids Uganda: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

Care4Kids Uganda’ is one such Member, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

In response to a draft of this review, Colleen Kelly said ‘Thank you for the review of our Charity’.

The charities’ regulator, the ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘Care4Kids Uganda’[3], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[4].

1.    A search on the ACNC Register of charities leads to a charity called International Support Aid Australia. This is because that charity has ‘Care4Kids Uganda recorded under ‘Also known as’[5].

2. NA

3. The “web address begins with ‘https’ and there is a closed padlock symbol next to the web address in the address bar”, so the website is secure [the first ACNC article above]. Although the page says that you can give online via credit card, there is no such facility on or via that page, so an assurance on the giving page about the safety of your information is not required.

4. The Australian Business Register (linked from Care4Kids Uganda’s ACNC Register record), says that the charity is not entitled to receive tax deductible gifts. It is a registered charity though.

But the Register is contradicted by the information on the ‘Donate’ and ‘Our work’ pages on the Care4Kids’ website:

Care4Kids offer no explanation for this contradiction.

5.    Here’s what they do. And what they did in 2017 (from the AIS 2017):

Empowerment of marginalised and disadvantaged individuals, orphans, vulnerable children, widows, families and communities through education and sustainable project opportunities. Building capacity and selfsufficiency by way of income generating schemes, micro-enterprise development and training, reducing poverty and offering families & individuals a better life with dignity and self-reliance. C4Kids Social Workers work with families and communities to develop individualised family plans to assist families and strengthen the family unit to work together in their projects to become sustainable and self-reliant. They regularly visit reintegrated children and families both in their home and in their educational environments. The Care

Preschool and Vocational Training Centre offers access to education/training for individuals and families that otherwise might never have access to education. Ongoing professional development of Care4kids National Staff enhances and strengthens the work of Care4Kids and provides new skills for staff that can enhance their capacity outside of their employment at Care4Kids. Families, Guardians and Community Members are able to access support from Care4Kids to strengthen and assist them with the problems associated to vulnerability and family breakdown.

The information on the website appears to be out-of-date.

There are no results, outcomes or impact reported on the ACNC Register or the website.

89% of the resources consumed in 2017 are described as ‘Project expenses’ in the Financial Report[6]. From the AIS 2017 we know that these are grants, predominantly to overseas entities. But to whom they were made is not disclosed, nor do Care4Kids say anywhere how they ensure that your donations are used for the intended purpose.

 

  1. https://missionsinterlink.org.au/about/http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  2. See here for last year’s review.
  3. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?Would you like to spend your money, or time if volunteering, to support these objectives?

    Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

  4. It is a business name held by the charity.
  5. Because of Care4Kids’s size, no Financial Report is required. And because it was submitted voluntarily, it does not need to comply with the ACNC’s requirements. And it doesn’t. Nor by any reasonable interpretation of ‘appropriate’ does it satisfy Mission Interlink’s requirements. Here’s the main shortcomings:
    • The financial statements are short one statement, a cash flow statement.
    • The Notes to the accounts are missing most of the required notes.
    • The person who ‘reviewed’ the accounts, A B (Brian) Ross, has produced a report that is nothing like the one required by his profession.

 

YWAM Perth: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

YWAM Perth’ is one such Member, and an organisation that seeks donations from the public on its website.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

The charities’ regulator, the ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘YWAM Perth’[3], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[4].

1.   A search on the ACNC Register of charities gives no results[5]. The website linked from Missions Interlink is in a different name, ‘Youth With A Mission Perth’. An ACNC search on this name still gives no results. But an ASIC search on this second name shows that the name of the organisation is actually Youth With A Mission (Perth) Incorporated (YWAMP). There is a registered charity in this name.

One shouldn’t have to go through these hoops to check on an organisation that’s seeking your money.

YWAMP has not registered any of the names it uses instead of its legal name as business names[6].

A search of the register using the legal name shows that there is another charity that includes ‘Youth With A Mission (Perth) Incorporated’ in its name, Youth With A Mission (Perth) Incorporated as the operator of a PBI. This charity is controlled by YWAMP, but must report separately. Its reports are well overdue.

There is no mention of the PBI (public benevolent institution) on the website.

2. NA

3. The “web address begins with ‘https’ and there is a closed padlock symbol next to the web address in the address bar”, so the website is secure [the ACNC article above].

There is no information about the security of your information credit card and other information on the first page of the ‘Donate’ page.

4. The Australian Business Register (linked from YWAMP’s ACNC Register record), says that YWAMP is entitled to receive tax deductible gifts, both as an organisation and as the operator of a fund, Youth With A Mission Western (Perth) Inc School Building and Maintenance Fund.

There is no mention of this tax deduction on the website.

5. See ‘Mission’ here for what they do.

No report of 2017 activities and outcomes is available because the AIS 2017 has still not been lodged, eight months after their year-end (it is two months overdue).

No Financial Report for 2017 is available because it is also overdue.

There is no information on outcomes, results or impact on the website.

 

 

  1. https://missionsinterlink.org.au/about/http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  2. See here for last year’s review.
  3. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?

    Would you like to spend your money, or time if volunteering, to support these objectives?

    Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

  4. It holds only one business name, ‘YWAM Training Perth’.

 

Bridgeway Publications: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

Bridgeway Publications’ (Bridgeway) is one such Member, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

The ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name.
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘Bridgeway Publications’[3], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[4].

1.  A search on the ACNC Register of charities leads to a charity in the name Bridgeway Publishing Foundation Trust. This is because that charity has ‘Bridgeway Publications’ recorded under ‘Also known as’[5].

2.  NA

3.  The “web address begins with ‘https’ and there is a closed padlock symbol next to the web address in the address bar”, so the website is secure [the ACNC article above]. Online giving is not offered, so an assurance on the giving page about the safety of your information is not required.

4.  Although Bridgeway is not entitled to receive tax deductible gifts, it is a registered charity.

5.   Here is what they are about: “BRIDGEWAY PUBLICATIONS is an Australian non-profit foundation that provides reference books and other resources to help Christians in the developing world.” Read more here.

There is a list of the countries to which it sent resources in 2018 in the AIS 2018, but this is extent of the disclosure of results, either on the website or on the ACNC Register.

There is no Financial Report 2018 because Bridgeway has the special status of ‘Basic Religious Charity’. This probably also explains the zeroes in the ‘Income and Expenses’ section of the AIS 2018. The status continues this year even though Bridgeway’ size has grown to Medium.

Bridgeway could have voluntarily lodged their report with the ACNC, but they chose not to.

The trust deed requires an annual audit – which implies the preparation of financial statements.

Although not mentioned on the website, their membership of Missions Interlink requires them 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]. In the review before last, Bridgeway commented that We have no issue with fulfilling Mission Interlink’s requirements and have provided appropriate financial information on supporter’s requests in times past.”

Bridgeway offers no information about their impact.

 

 

  1. https://missionsinterlink.org.au/about/ 
  2. http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  3. See here for last year’s review.
  4. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?Would you like to spend your money, or time if volunteering, to support these objectives?

    Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

  5. ‘Bridgeway Publications’ is a business name owned by a partnership:These three men are three of the five men who are currently the responsible persons for the charity. Last year, Bridgeway showed me that the partnership consisted of all five of the responsible persons at the time. Is this still the case?

 

Wycliffe Australia: charity review

This is a review in the series ‘Members of Missions Interlink, Missions Interlink being ‘the Australian network for global mission[1] (and a means for a Member to get income tax exemption when it might not otherwise be available[2], with a consequent accountability regime).

Wycliffe Australia’ is one such Member, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

The ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here’s the results for Wycliffe Australia, with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[3].

1.  There is no registered[4] charity in that name[5] (ACNC Register). The website that Missions Interlink links to is in the name ‘Wycliffe Bible Translators’. Searching the Register on that name leads to Wycliffe Bible Translators Australia[6](Wycliffe).

Wycliffe has not registered the name that it uses most prominently on its website. (Nor the other two names it uses there.)

2. NA

3. The “web address begins with ‘https’ and there is a closed padlock symbol next to the web address in the address bar”, so the website is secure [the ACNC article above]. For specific comfort when you are entering your information in order to donate, these logos are provided:

However, they are not linked to any information.

4. Although Wycliffe is not entitled to receive tax deductible gifts, it is a registered charity.

Its ineligibility does not fit with the information under ‘Donate’:

No explanation of this inconsistency is given to online donors.

5.  The audited account of how the donations are used is the Financial Report 2017 on the ACNC Register. Within that there are two statements that give information on how the donations were used. Most donors think in terms of cash, so if that’s you, you might turn first to the Statement of Cash Flows. What you might now know though, is that you first should turn to the Notes to the accounts (Notes to the Financial Statements in this case) to check out the ‘Basis of preparation’.

Do you provide or give things to, receive things from, or have oversight of, or review, of the Wycliffe[7]? Perhaps you intend to donate or are one of the donors who gave some undisclosed amount[8] last year [Financial Report 2017]? Perhaps you are one of the suppliers or employees who shared in the $1.89 million of payments? [Financial Report 2017], or one of their 302 staff [AIS 2017]. If so, can you ring Wycliffe’s office and request that they prepare financial statements that answer the question or questions you have about the charity? I very much doubt it. You are therefore ‘potentially interested in the information provided in general purpose reports’.

You are therefore in the wrong place – I only have access to the published accounts of Wycliffe, and the directors[9] have again declared that you don’t exist:

________________________________________________________

If Wycliffe is still in the running for your business –

  • The charity that they control, by being its only member, Wycliffe Relief and Development Foundation Ltd, is not consolidated by Wycliffe. (It is not even mentioned.)
  • The auditor, Matthew Hung, CA, of rdl.accountants, agrees with the decision that there are no users who are dependent on general purpose financial statements.
  • There are multiple giving options, but the report of resources consumed during the year (where your money went), shows just these two lines, without further explanation, for over 63% of the expenses:
    • ‘Operating expenses’ $1.20 million
    • ‘Program expenses’ $272K.
  • So, there is no information to give you comfort that the money that you will give will be spent on the purpose you gave it for.

Wycliffe did not respond to a draft of this review.

__________________________________________________________

Contact me if you need a more in-depth review.

 

 

 

  1. https://missionsinterlink.org.au/about/http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  2. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?

    Would you like to spend your money, or time if volunteering, to support these objectives?

    Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

  3. The ACNC implies, therefore, that it is a ‘legitimate’ charity. But this is not correct – as the ACNC itself points out, registration is voluntary.
  4. Nor an ABN or a business name.
  5. See here for last year’s review.
  6. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au: http://tedsherwood.com/wp-content/uploads/2018/08/word-image-15.png  
  7. Presumably donations are included in the $1.31 million of ‘Operating income’.
  8. The people shown under ‘People’ here.

 

Steer Incorporated: charity review

Mini charity review of Steer Incorporated (Steer)

The previous review (in black) is used as a base, with comment only if the situation has changed or extra information would be helpful.

as an organisation that seeks donations. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

2018 review:

  • Steer is still a Member of Missions Interlink[1], an organisation that gives Members an income tax exemption[2].
  • Members of Missions Interlink have to accept a set of standards, the introduction to which includes this statement:

Are they responsive to feedback?[3]

  • When sent a draft of this review, they did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is Steer registered?

  • As a charity, yes.
  • Other registrations:
    • As a public company, a company limited by guarantee (despite the ‘Incorporated’ in its name).
    • Not registered for fundraising in any of the seven six states that have a fundraising licence regime. This includes the five states in which Steer operates (or eight if we go by their AIS 2015).
      • The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.

What do they do?

  • You place – either give or sell – income-earning assets with them; they manage these assets and distribute the income, tax-free, to missions.

Do they share the Gospel?

  • No

What impact are they making?

  • Nothing found.

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

  • If ‘direct’ is defined as ‘Gifts to missionary organisations’, then 15% 16.4%.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA.

Is their reporting up-to-date?

  • Yes (lodged five and a half months after their year-end).
    • 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 five months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015 AIS2017 : Not quite. There are no outcomes given, and a number of the figures in the Income Statement do not match those in the Financial Report.
  • Financial Report 2015: No
    • There is no audit report.
    • The directors have decided that Steer, an organisation that received $4.76 m in revenue, including $2.42 m in gifts, operates in five (maybe eight) states, and appeals publicly for donations, has no users, either present or prospective, who rely on the financial statements to make decisions. This means that they can produce special purpose financial statements, statements that do not have to comply with all the Accounting Standards.
    • Two of the programs for donors are the leasing, at a peppercorn rental, of agricultural land and rental properties.
      • There is no split between the two types of properties.
      • There is no identification of these leases as either operating or finance.
      • There is no policy note on accounting for the rental payment – is it just the peppercorn amount?
    • Another of the programs is ‘Livestock and wool’. This program results in Steer taking ownership, either for no consideration or some, presumably nominal, consideration, of livestock.
      • These livestock are not included in the accounts. Steer says that the geographical location and diversity of these assets mean that valuation is not worth the effort. However, while this may make valuation subsequent to purchase difficult, it does not preclude valuation at the time of acquisition. The value, and if not the value then the cost, would be known at that time.
        • Even if it is still decided not enter figures for the livestock holding, some indication of the type and number of animals would allow at least a rough estimate by a reader.
    • 2018 review:
      • Revenue is now $8.13 million, including gifts of $3.17 million, and yet the directors persist with the untenable position that ‘there are no users who are dependent on [its] general purpose financial reports’. So if you are reading this then you are likely one of those people who the directors say don’t exist.
      • Where in the accounts are the properties that are leased?
      • Steer still doesn’t show a true and fair view about the livestock.

What financial situation was shown by that Report?

  • Last year’s surplus of 7% of revenue was increased to 19% this year, largely due to an increase in ‘Gifts’.
    • 2018 review: From 13% last year to 54% this year. There is no explanation given for not distributing more of the revenue.
  • Due to the practice of only seeking at call loans, their working capital is negative (that is, current (short-term) liabilities slightly exceed current (shot-term) assets.)
    • 2018 review: The ratio increased, from 1.1 to 1.9.
  • There is no consequential comment on the going concern assumption.
    • 2018 review: There is no longer a need for such a comment.
  • No obvious concerns about the longer term structure.
  • 2018 review: Other than overseas or Australia, there is no information about where the donations went.

What did the auditor say about the last financial statements?

  • NA. (No audit report.)
  • 2018 review: The auditor, Jeffrey Tulk, for Saward Dawson, gave a ‘clean’ opinion.
    • But this included acceptance of the directors’ decision to produce the financial statements suitable only if users can ring Steer and get a report tailored to their needs.
    • And the acceptance of the deficient information about the livestock.

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

  • Apart from blanks under ‘Phone’ and ‘Website’, yes.
  • 2018 review:
    • There is now a phone number, and a website address is not compulsory.
    • Most of the grants were to overseas organisations, but there are no countries under ‘Where the charity operates’.
    • Most of the directors are missing from the ‘Responsible People’ section.

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

  • They have six programs:
    • You make an interest-free loan to them.
    • Your family or discretionary trusts makes a distribution to them
    • You rent your investment property to them for $1 p.a.
    • You either give or sell your livestock to them. (They pay you to raise it.)
    • You lease your farm land to Steer at a peppercorn rental. It is then share farmed.
    • ‘Bequests’

Who are the people controlling the organisation?

  • The five men shown here include three of the four directors.
    • Although Terence Crook is included in the list on the ACNC Register, he is not a responsible person.
  • 2018 review: The governing document says that Steer is controlled by the Council. The members of the Council are shown here.
    • The relationship between the ‘Directors’ and the ‘Board Investment subcommittee’ shown on the same page is not explained.
    • The ACNC Register incorrectly shows only the three ‘Directors’ as the responsible persons.

To whom are they accountable?

  • As they claim on the website, they are, apart from being accountable to the ACNC, accountable as a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • 2018 review: They are also, for some things, accountable to ASIC.

 

 

 

  1. In the name ’Steer Inc’. (For an incorporated association this wouldn’t be an issue, but Steer is a company, and therefore ‘Incorporated’ is part of its legal name.
  2. Even though they do not meet the “in Australia” test and do not have deductible gift recipient status.
  3. This section was originally at the end of the review.

 

People International Australia Inc: charity review

Mini charity review of People International Australia Inc (PIA),

The previous review (in black) is used as a base, with comment only if the situation has changed or extra information would be helpful.

as an organisation that seeks donations online, and is exempt from Australian income tax via its membership of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Members of Missions Interlink have to accept a set of standards, the introduction to which includes this statement:

For the previous review, see here.

Are they responsive to feedback?

  • I sent them a draft of this review on 16 August 2017. They…did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is PIA registered?

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

What do they do?

  • The Annual Information Statement (AIS) 2016 says they
    • Raised funds to support gospel work in Australia and overseas.
    • Last year they raised $164K and sent $27K. $120K went on the two full-time employees.
    • 2018 review:
      • The AIS 2018 gives the ‘activities and outcomes’ as ‘Raised funds and provided opportunities to support gospel work in Australia and overseas.’
      • They raised $159K and sent $48K. $121K went on one full-time and one part-time employee.
  • ‘About Us’ on the website is about the international organisation.

Do they share the Gospel[1]?

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

What impact are they having?

  • Nothing found.

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

  • There are no financial statements, but from the Annual Information Statement (AIS) 2016 AIS 2018, expenses other than ‘Grants and donations made…’, that is, expenses on ‘administration’, are 84% 75% of the total.

Do they pay their directors?

  • There are no financial statements, and it’s not possible to tell from the limited information disclosed in the AIS 2016 AIS 2018 But if they did pay them, it wasn’t much.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

Where were your (net) donations sent?

  • People International globally is a mission to the twelve countries of Central Asia, but PIA is only involved, per the ACNC Register, in one country, Pakistan.
  • 2018 review: Now also Turkey.
  • We are not told to whom donations are sent in Pakistan.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Yes
  • 2018 review:
    • ‘Legal Name’ is incorrect.
    • ‘Other names…’ is incorrect.
    • ‘Main beneficiary’ (General community in Australia’) is incorrect.
  • Financial Report 2016 (2018): NA
    • As a ‘Small’ charity, PIA doesn’t have to submit a Financial Report.
    • And it chose not to submit one voluntarily.
    • As a Victorian incorporated association, at least financial statements should have been prepared though:
      • As soon as practical after the end of your incorporated association’s financial year, the committee must ensure that financial statements are prepared.
      • And they ‘must give a true and fair view of its financial performance and position during and at the end of the year.
    • As a member of Missions Interlink, PIA is not only required to prepare financial statements, but it must have them audited:
      • have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor’ [Standards Statement, 4.1].

What was the financial situation shown by that Report?

  • NA
  • But from the AIS 2016:
    • 95% of ‘Revenue/receipts’ was from ‘Donations and bequests’, down from 100% last year.
    • ‘Employee expenses/payments’ have risen from 29% of expenses to 70%.
    • PIA reported that its accounting method was ‘Cash’, a method that doesn’t generate liabilities; therefore, they had to record these outside the double entry system.
    • 2018 review:
      • Because of $50K of ‘Other revenue/receipts’, ‘Donations and bequests’ were only 76% of receipts
      • ‘Employee expenses/payments were 64% of payments.

What did the auditor say about the last financial statements?

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

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

  • Yes
  • 2018 review: No
    • The name is incorrect.
    • It maybe ‘known as’ ‘People International Australia Inc’, but this is because it is its legal name.

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

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

Who are the people controlling the organisation?

  • There is no mention of the board on the website.
  • From ACNC Register (under ‘Responsible Persons’):
    • Darryl Anderson
    • Rachel Driessen
    • Stephen Ellis
    • Moussa Ghazal
    • David Lewis
      • There are 13 directorships recorded for the name ‘David Lewis’.  And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  Therefore, if after eliminating the charities for which David is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.
    • 2018 review:
      • Driessen has gone, and Bonnie Lepelaar and Robert Morris have joined.
        • Is it this Robert Morris?
      • A search of responsible persons is not possible with the new (ACNC) website.

To whom is PIA accountable?

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

 

 

 

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