On the trail of how a church with its own law works

One of the pieces of information that the legislators made compulsory for the ACNC Register was ‘the entity’s governing rules’. Almost always a constitution, rules or trust deed.

I need this document to complete a review of a charity.

For the Presbyterian Church of Australia Aust Presbyterian World Mission Committee – yes, that’s its name – the Register showed me this:

Not the usual title of a governing document: first, they are not usually made especially for the ACNC, and second, it is usually a single document not ‘documents’ plural.

The ‘Description’ here is because the charity is a particular type of religious charity. So twice special.

Presbyterian Church of Australia Aust Presbyterian World Mission Committee is a charity whose ‘governing documents are a reference to the legislation that creates [its] organization, or to church or canon law.’ In this case, the ACNC says that they only need to provide a link to the laws, not a copy of them.

So that’s what’s in the .pdf document above:

The link leads, not to the documents, but to the website of Presbyterian Church of Australia in the State of New South Wales:

So one searches for the documents. (At least this charity has a search function; too many don’t). Don’t make the mistake that I made, though, quickly read the .pdf and search for ‘The Code’. The result is a discouragement to go further:

Luckily I rolled below the fold and found something much closer to what the ACNC want you to find:

A search on ‘Constituting Documents’ takes you straight there.

‘Constituting Documents of the PCNSW’ has been put in one document for you:

You might ask, then, why couldn’t this document be lodged on the Register? Was it in the mind of the legislators that sometimes the user will be sent on an internet trail in order to get basic information about how the charity works? Ignoring that, if there is a good reason why the document can’t be lodged on the Register, how about giving a link to it instead?

Now to the task of finding what I want in the 481 pages.

ACC International Relief Inc.: mini-charity review

Mini-charity review of ACC International Relief Inc. (ACCIR), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Are they responsive to feedback?

  • ACCIR welcomes it:
    • ACCI recognises that listening to and responding to feedback, concerns and complaints is integral to our commitment to achieving the high standards and ensures accountability to all stakeholders. Complaints or feedback can be submitted to the CEO of Operations via the below contact details or to another ACCI employee, field worker or strategic partner. 
  • I sent them a draft of this review. Like last year, they…did not respond.

Is ACCIR registered?

  • As a charity, yes. (But as Acc International…)
  • As a Victorian incorporated association (A0008672W).
  • Although it has not shown them on the ACNC Register, ACCIR has three business names: Kinnected, AOG World Relief, and AUSTRALIAN CHRISTIAN CHURCHES WORLD RELIEF.
  • ACCIR operates – according to the ACNC Register – throughout Australia. And has an internet invitation to give.
    • It has the necessary ARBN registration (26 077 365 434) to carry on business interstate.
    • It is not registered in three of the six states that have a fundraising licensing regime. No reason is given for this.

What do they do?

Do they share the Gospel?[1]

  • No. From the section ‘Beliefs’ on the website:
    • ACC International Relief carries out aid & development activities only. Evangelistic programs and activities are administered and funded separately through the organisation ACC International Missions.

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 ‘directly incurred’ as ‘Funds to international programs’, it is 9%. Are some of their expenses borne by another organisation?

Do they pay their board members?

  • This is not prohibited by the ACCIR constitution.
  • The expenses are not disclosed in sufficient detail to check for a payment.

Can you get a tax deduction?

  • Per the ABN record, yes, both to ACCIR and to its two funds, World Relief Fund and ACC Relief Fund.
    • But only the World Relief Fund is mentioned on the giving pages (e.g. donate).

Is their online giving secure?

  • Security is not mentioned.

Is their reporting up-to-date?

  • Yes (lodged four and a half months after year end, one 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 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Other Income’ does not match the figure in the financial statements.
    • A name that does not belong to them is included under ‘Other names…’, and three are omitted.
    • There is a description of their mission under ‘activities and outcomes’ instead of the year’s activities and outcomes.
  • Financial Report 2016: Probably. But
    • It is hard to see that a report that makes no mention of (a) the organization that supplies and controls the membership, Australian Christian Churches, and (b) the organization with which it shares a business name and a website, ACC International Missions Ltd, can be judged as showing a true and fair view.

What financial situation was shown by that Report?

  • Last year’s surplus of 3% of revenue was turned into a 1/5th% deficit.
  • ‘Cash and cash equivalents’ plus ‘Financial assets’ represents only a little over one month’s revenue.
  • No obvious concerns with financial structure.

Where were your (net) donations sent?

  • Other than overseas, we are not told where or to whom.

What did the auditor say about the last financial statements?

  • The auditor, Jeffrey Tulk, for Saward Dawson, gave a ‘clean’ opinion.
    • To take the right amount of comfort from a ‘clean opinion’, please read here and here.

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

  • No
    • ‘ACCI Relief’, under ‘Other Name(s)…’, is not a registered business name.
    • Their three business names are missing.
    • There are a couple of errors under ‘Responsible Persons’.
    • ‘Phone’ and ‘Website’ are blank (but these are not compulsory).

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

  • ‘Partner with a project
    • 7 under ‘Africa’
    • 9 under ‘Cambodia’
    • 5 under ‘South Asia’
    • 3 under ‘South East Asia’
    • 3 under ‘Vietnam’
  • ‘Become a RAISE partner’
    • ‘RAISE: Madagascar’
    • ‘RAISE: Mozambique’
    • ‘RAISE: Sri Lanka’
    • RAISE: Vietnam’
    • ‘RAISE: Kolkata’
    • ‘RAISE: Visions Rescue’
  • ‘Current Appeals’
    • ‘Middle East Crisis Appeal’
  • ‘Give to our One Day Campaign…’
  • ‘Bequests…’

Who are the people controlling the organisation?

  • See the list at the bottom here.
  • The ACNC Register (under ‘Responsible Persons’) has an additional person, Allan Davis and ‘Alan’ instead of ‘Alun’:
    • Ishara Davey
    • Alan Davies
    • Allan Davis
    • Karyn Ey
    • Kruithoff Ian (should be the other way round)
    • Kristy Mills
    • Terri Reid
  • The board is responsible to the members. The number of members is not disclosed.

To whom are ACCIR accountable?

  • As a charity, to the ACNC.
    • ACCIR displays the ACNC’s ‘charity tick’ in the website footer.  This is used in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means ACCIM’s AIS is not overdue, and no compliance action has been take against it.
      • But it means no more than this.
  • As an association, ACCIR is accountable to the Victorian regulator of incorporated associations.
  • Although not claimed on their website, nor under ‘Accountability’ in the Annual Report, they are accountable as a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • Membership of the ACFID claimed. Confirmed. This means they must follow the ACFID Code of Conduct.

 

 

  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.

Wise Choices for Life Inc: mini-charity review

Mini charity review of Wise Choices for Life Inc (WCL), an organisation that seeks donations online and is an Associate member of Mission Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For last year’s review, see here.

Is it responsive to feedback?

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

Is WCL registered?

  • As a charity, yes.
  • As a Victorian incorporated association (A0056675X).
  • WCL doesn’t hold any business names yet they routinely use their name without ‘Inc’ or ‘Incorporated’.
    • It may well be that some of this use also contravenes the requirements of their enabling legislation.
  • WCL operates, per the ACNC Register, in all states.  It 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 not have a fundraising licence in its home state, or any of the other five states that have a licensing regime[1].

What do they do?

Do they share the Gospel?[2]

  • Despite their name, no, they don’t.

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 financial information is publicly available.

Do they pay their board members?

  • Neither constitution nor a profit or loss statement is available to check.

Can you get a tax deduction?

  • Yes
    • Below is an extract from a newsletter. What is the relationship between International Needs Australia (the renamed International Needs), WCL, and tax?

Is their online giving secure?

  • PayPal is used, so yes.

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

  • If you wanted to use the online facility, you would need to know that the choices for your money are given in the bank transfer section later on the page:

Is their reporting up-to-date?

  • Yes. (Four months after year end, about the same time as last year.)
    • However, given that their financial year ended seven months ago, it would not be unreasonable to ask them for an update (especially if your proposed donation is large).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Apart from the lack of outcomes, yes.
  • Financial Report 2017: NA – because of their size, they don’t have to lodge one. (They lodged one last year.)
    • 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.” No such statement has been made public.

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • NA

Where were your (net) donations sent?

  • No information is disclosed.

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

  • Yes

Who are the people controlling the organisation?

  • Per the website, the people here.
  • But the list on the ACNC Register (under ‘Responsible Persons’) still has a Janice Smith, and now no Janice Kreltszheim:

To whom is WCL accountable?

  • As a charity, to the ACNC.
  • And as an association, to the Victorian regulator of incorporated associations.
  • To Missions Interlink via their Associate membership.
    • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  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.

Missions Interlink NSW: mini-charity review

Missions Interlink NSW (MIN) is of interest because one of its ‘responsible persons’ (ACNC), Judith Kay, is also a director of the organisation[1] that runs Missions Interlink, a body that, until recently[2], was the only ‘Christian’ body requiring accountability of its members.

MIN is registered as a charity. But should it be? Its ABN was cancelled from 1 October 2017, and the ACNC won’t register a charity that doesn’t have an ABN.

Missions Interlink NSW is a State branch of Missions Interlink. When I reviewed MI two years ago, I commented that ‘There is no explanation of why the Victorian branch deregistered, or why the other State branches are not registered. (Or, alternatively, why NSW is still registered.)’. So, it is no surprise that in the MIN Annual Information Statement (AIS) lodged last month, they said that in 2018

MI NSW will continue to operate the same activities but its ACNC registration will be voluntarily revoked and its reporting consolidated with AEA Inc. Mission Interlink’s registration.

It lodged its AIS 2017, for the year ended 30 June 2017, on 4 January 2018, so presumably it did not expect any revocation to take effect until after that AIS was due, on 31 January 2018.

No Financial Report 2017 had to be lodged, nor financial information included in the AIS. This is a consequence of MIN being a ‘basic religious charity’. It also doesn’t have to comply with the ACNC’s governance standards.

The ACNC Register, under ‘Responsible Persons’, says that these are the committee members of MIN:

John Ackad

Magda Ackad

John Anderson

Warwick Coghlan

Judith Kay

Margaret Love

Rhianna Miles

Philip Morris

Pamela Thyer

Kephas Wong

An update of the review of the national Missions Interlink organization is well overdue. I will speak to the person responsible.

 

 

  1. Australian Evangelical Alliance Incorporated.
  2. Now we have the CMA Standards Council.

The Bible League Incorporated: mini-charity review

Mini charity review of The Bible League Incorporated (TBL) an organisation that seeks donations online and that is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(For the previous review, see here.)

Are they responsive to feedback?

  • Neither feedback nor complaints is mentioned on the website.
  • I sent them a draft of this review. Like last year, they did not respond[1].
    • Some changes that they have made after receiving the draft suggest that they did respond, just not to me.

Is TBL registered?

  • As a charity, yes.
    • With TBL’s website being in the name Bible League International, don’t confuse TBL with the charity Bible League International (APAC) Pty Limited, or the US Bible League organization Bible League International.
      • Bible League International (APAC) Pty Limited is indirectly related to TBL, being a wholly-owned subsidiary of the US organization. It receives revenue almost entirely from the parent, and after expenses (28% last year), distributes it in the Asia-Pacific region.
    • TBL also trades under the name Bible League Australia. They have registered this name.
    • Ten times on the website it also refers to an entity called Bible League Australia and New Zealand. This is a business name belonging to TBL. But there is no combined organization[2].
  • Other registrations:
    • As a NSW incorporated association (Y2857836). (Not, as TBL is still saying on the Australian Business Register, an ‘Other Unincorporated Entity.)
    • TBL operates – according to the ACNC Register – throughout Australia.
      • If it’s ‘carrying on business’ outside NSW, as it appears to be, then it still doesn’t have the required registration (an ARBN).
      • It is registered to fundraise in all states that have a licensing regime except for Western Australia and South Australia. Presumably it still believes that is exempt in these two states.

What do they do?

  • Not what the website or the Committee’s Report (in the Financial Report) says – that’s about the international effort. But what was again said in the AIS before they changed it recently[3]:
    • Fundraising through marketing to supply bibles.

Does they share the Gospel?[4]

  • No.

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 ‘Distribution of Funds Raised’ then 52 cents of every dollar of expenses is administration. Last year it was 45 cents.
    • ‘Employment expenses’ are 31% of total expenses. Last year it was 27%.
    • No explanation is given for these significant increases.
    • It would be reasonable to ask TBL why it would not be more efficient for you to send your donation direct to the US organisation.

Do they pay their board members?

  • Such payments are not prohibited by the constitution.
  • From the (unaudited) Detailed Income and Expenditure Statement, the only item possibly relevant is Committee expenses $3K.

Can you get a tax deduction?

  • No
    • But if that’s critical for you, TBL say that there may be a solution:
      • However, businesses are able to gain some tax advantages by supporting the ministry through a business sponsorship.

Is their online giving secure?

  • eWay is used, so yes.

Is their reporting up-to-date?

  • Yes (a little over three months after their year-end, 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 15 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No.
    • Again, this year
      • Two of the figures in the Income Statement do not match those in the Financial Report.
      • No outcomes are given.
    • TBL is incorporated in one state, not four.
  • Financial Report 2017: No
    • The directors still don’t say why they have chosen to produce the lower disclosure special purpose financial report. But whatever their reasoning, such a report, one that assumes that all TBL’s stakeholders, both present and prospective, are capable to getting TBL to produce a report tailored for their purposes, is not, for a charity that collects $3.0 m from donors all over Australia, consistent with the required true and fair view.
    • TBL has the same directors as Bible League International New Zealand, collects money for it, and appears to keep its books. Yet the relationship is not mentioned.
    • TBL continues to produce a Report that
      • excludes ‘Other Comprehensive Income’,
      • omits some necessary Notes to the accounts,
      • includes negative depreciation without an explanation,
      • makes an incomplete or incorrect disclosure about land and buildings and financial assets,
      • uses a mixed classification of expenses,
      • includes a second profit or loss statement without explanation,
      • refers to ‘authoritative pronouncements of the Associations Incorporation Act’, and
      • provides an audit report that excludes one of the required statements from its scope.

What financial situation was shown by that Report?

  • Last year’s result of slightly over zero surplus was converted into a 1% deficit this year.
  • No obvious concerns with the financial structure.

What did the auditor say about the financial statements?

  • The auditor, WJ Piepers FCA, for berger piepers, Chartered Accountants, gave a ‘clean’ opinion.
  • Before you conclude on how much comfort you should take from this opinion, please
    • read on the meaning of ‘clean’ here and here, and
    • re-read the section ‘Financial Report 2017’. (To do the audit, WJ Piepers had to be comfortable with the directors’ decision to not produce general purpose financial statements.)

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

  • No:
    • ‘Operates in (Countries)’ is blank. Money is sent to the US and New Zealand, and the same people run both the Australian and New Zealand Bible League organisations.

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

  • The following areas for ‘My Gift to Plant Bibles’:
    • Where Most Needed’
    • ‘Ethiopia – Making a Dream Come True’
    • ‘Middle East – Planting God’s Word’
    • ‘Ethiopia – eNews’
    • ‘Philippines – eNews’
    • ‘Bibles for the Persecuted’
    • ‘Bible League Friend’
    • ‘Run4Bibles’
    • ‘New Zealand Purposes’

Where were your (net) donations sent?

  • Note 1 in the Notes to the Financial Statements says that
    • The Associations (sic) origin likes in raising funds for the distribution of the Gospel as shown in the Committee’s Report[5]. The cost of distributing the Gospel is borne by The Bible League in the United States of America. It is understood between the parties The Bible League Incorporated retains sufficient funds to enable it to continue with the task of fund raising.
    • Beyond this, there is no disclosure.

Who are the people controlling the organisation?

  • Not shown on the website.
  • Per the ACNC Register (under ‘Responsible Persons’):
    • Arie Baalbergen
    • Raymond Condon
    • Donald De Vries
    • Blayne Herr
    • Peter Knight
    • Dirk Reitsma
    • Jarrod Thompson
    • The same people are the directors of Bible League International New Zealand.
  • The directors are responsible to the members of the association. The number of members is not disclosed.

To whom are TBL accountable?

  • As a charity, to the ACNC.
  • As an association, to the New South Wales regulator of incorporated associations.
  • Membership of Missions Interlink, an organisation that has a general accountability regime, is claimed on the website. Confirmed.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • Membership of FIA, an organisation that has a fundraising code of practice, is claimed on the website. But TBL are (still) not in the list of members.

 

 

  1. Bible League in Australia continues to maintain the highest level of financial integrity. We are committed to financial disclosure and trustworthy stewardship [From their bequest promotion brochure, https://bl.org.au/wp-content/uploads/2014/04/The_Enduring_Word_AU_Web2.pdf].
  2. The history on the website records that Bible League Australia and BiblesinAction (NZ) merged on 1 September 2012. The New Zealand charity Bible League International New Zealand was registered three months later. But there is no mention of a combined organisation under ‘Global Offices’ on the TBL website, nor in the Financial Report. TBL’s website has a button to go to the New Zealand site, and vice versa.
  3. It now says ‘Present the Gospel of the Lord Jesus Christ through the distribution of Scriptures to churches, individuals and homes without Bibles globally.’
  4. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  5. No, that Report says that ‘The principal activity of the association during the financial year was to present the Gospel of the Lord Jesus Christ through the distribution of Scriptures to churches, individuals and to homes without Bibles.’

The curious case of Whitley College

One of my review series is ‘members of Missions Interlink’. Back in early January I noticed that a ‘Whitley College’ had become an Associate member:

The link in that list led to this website:

Due to the charitable purposes of such an organization, one would therefore expect to find it on the ACNC Register. But a search drew a blank:

So, given that it would be exceptional if such an organization didn’t have an ABN, I went to ABN Lookup. Here it told me that ‘Whitley College’ was indeed a charity – although with a longer name. (That should make no difference to the ACNC Register search – it will bring up any charities with ‘Whitley College’ in the name.)

The ACNC Register can be searched using either a name or an ABN. So, using the name…I again drew a blank.

The Advice Team at the ACNC were their usual responsive self, and within a day or so I had the answer to the mystery:

Once a withholding request is submitted by a charity, the entire record is withheld in case the charity has requested a lower than appropriate level of withholding. We do this blanket hold (temporarily remove public access) for the safety of the charity, its responsible persons, and/or its beneficiaries.

That’s a drastic solution ACNC.  Thoughtful, but drastic.

You can read about withholding information here.

Given that ‘There are limited circumstances when we may withhold a charity’s information from the Register.’, and that you’ll get a refusal if ‘the public interest in displaying the information outweighs the likely adverse effect of’ the circumstance’ that the charity thinks warrants the withholding, one wonders what reason a Baptist bible college has to withhold any of its information.

The bad news for the public – but good for any charities wanting to use the withholding provision for the wrong reasons – is that, nearly a month later, the record is still not available.

PS ‘Whitley College’ is not a name that the Baptist College is registered to use:

Elam Ministries: mini-charity review

Mini charity review of Elam Ministries (Elam) an organisation that seeks donations online and that is an Associate member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • When sent a draft of this review[1], they…did not respond[2].

Is Elam registered?

  • No, not in Australia.
    • Their membership of the Australian organization Missions Interlink suggests that they have an organization in Australia, but none could be found. Not even an ABN.
      • How did they get membership of Missions Interlink?
    • As a ministry seeking to extend Elam Ministries (US and UK) to Australia, it is highly likely that they are a charity, just not a registered one. Therefore, they are not exempt from tax.
    • This article, a post on it on their Facebook site, and Fiona Baird’s LinkedIn profile, are the only references to their Australian presence I could find.
      • Her profile says that she has been the ‘Regional Director’ since July last year.
  • The website linked from Mission Interlink’s membership list covers two ‘offices’, Elam Ministries, UK, and Elam Ministries, US. But no Australian office.

What do they do?

  • Other than the information above, nothing found

Do they share the Gospel?[3]

  • No

What impact are they having?

  • No information found.

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

  • No information found.

Do they pay their board members?

  • No constitution to check.
  • No financial information found.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA (Australia).
    • Security is not mentioned on the UK/US website’s giving page.

Is their reporting up-to-date?

  • NA (no organization registered).

Does their reporting comply with the regulator’s requirements?

  • NA

What financial situation was shown by that Report?

  • NA

What did the auditor say about the financial statements?

  • NA

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

  • NA

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

  • NA (Australia).
    • See here for the US/UK organization’s choices.

Where were your (net) donations sent?

  • NA.

Who are the people controlling the organisation?

  • No information on a board of directors found

To whom are Elam accountable?

  • No accountability found other than which comes with membership of Missions Interlink.

 

  1. Having no Australian contact address, I messaged them on their Facebook page to ask how they got Missions Interlink membership without an Australian entity. They replied asking for my email address so that Fiona could respond to me. She didn’t. Later I sent the draft review on Facebook, but although the message was read (on 15 January), nobody has responded.
  2. Neither complaints or feedback are invited on the website.
  3. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

Entheos Incorporated: mini-charity review

Mini charity review of Entheos Incorporated (Entheos), an organization that seeks online donations, and is an Associate member of Missions Interlink.

Are they responsive to feedback?

  • If sent them a draft of this review. The comments that they sent in response have been included below.

Is Entheos registered?

  • Yes, as a NSW incorporated association (INC9875826).
  • But not as a charity.
    • As it is clear from their website that they are a charity, the lack of registration means that they are not entitled to any charity tax concessions.
      • Ministry comment: ‘None of the work we do qualifies for charitable status.
        • Reviewer response: A confusion of charitable purpose and tax-deductible status?
  • Not registered for GST, so this should mean that its gross income is below $150K.

What does Entheos do?

  • See here.
    • Ministry comment: ‘Because we have been living and working in and taking teams to sensitive places we keep out website deliberately vague.’

Do they share the Gospel?

  • The ‘mission exposure teams’ do.

What impact are they having?

  • No information found.

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

  • No financial information is published, so it is not possible to make this calculation.

Do they pay their board members?

  • No constitution publicly available to check.
  • No financial statements publicly available to check.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

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

  • None – just a ‘purchase’.

Is their reporting up-to-date?

  • Check with the associations regulator, Fair Trading.
    • Ministry comment: ‘All our financial reporting is up to date with Dept. of Fair trading etc.

Does their reporting comply with the regulator’s requirements?

  • Not a charity, so you need to check with Fair Trading.
  • The submission to Fair Trading may or may not satisfy the Missions Interlink requirement for Entheos to “have…a clear and appropriate financial statement which has been approved by its auditor.” 
    • Even if it does, it is not available for free, so doesn’t satisfy the spirit of the Missions Interlink requirement for that statement to be ‘available for [their] members and supporters’. Just ask them for it.

What financial situation was shown in that Report?

  • I did not ask Fair Trading for a copy – it costs.

What did the auditor say about the last financial statements?

  • An audit report may or may not have been lodged with Fair Trading.

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

  • NA

Where were your (net) donations sent?

  • No financial information is published.

Who are the people controlling the organisation?

  • Not shown on the website.
  • Presumably the founders, ‘Craig & Jackie’ Gibbon are two of the board members. Other than that, check with Fair Trading.
    • Ministry comment: ‘Entheos continues and does have a board: Ps Brent Williams (C3 Ryde), Ps John Van Bennekom (Springfield Christian Family Church), Mr Alan Blyth, Mr Joshua Gibbon and myself.’

To whom is Entheos accountable?

  • As an association, to the New South Wales regulator of incorporated associations.
  • To Missions Interlink via its Associate membership.
    • For one opinion on the strength of that accountability, see the section Activities in this review.
    • You might ask Missions Interlink whether it is acceptable for a member that is a charity to be not registered with the charities regulator.

International Village Care Ministry: mini-charity review

Mini-charity review of International Village Care Ministry (IVCM), an organisation that seeks donations online, and is an Associate member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the last review, see here.

Are they responsive to feedback?

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

Is IVCM registered?

  • They are a charity, but not registered as one.
    • This means that they are not entitled to any charity tax concessions.
  • Not incorporated.
    • This means that the members are personally liable for the actions of IVCM.
  • But IVCM has an ABN.
  • Lack of registration for GST is OK so long as their turnover is less than $15oK.

What does IVCM do?

  • Projects in India (three), and Cambodia (one).
  • For the review last year, they commented that ‘We are a relatively small group looking after around 180 children either in the homes in India or thru the Daycare Training centre in Cambodia.’
  • And in explanation for the lack of a record of an organisation called IVCM declaring the receipt of money in the year to 31 March 2015 to the Indian government, they commented ‘The work we do in India is run thru Global Developments…We have a FCRA under Eagle Trust our main trust in India that overseas our work. In Cambodia we have a MOU with the Government under IVCM for the work we do there.’
    • The record of the receipt of money for ‘Eagle Trust’ is a little hidden – the name is actually Enrich Accommodate Guide for Life and Education (Eagle) Charitable Trust.
    • Presumably this is the Global Development project?
    • Why the need for a third party, Global Development Group, when they have their own registration under the Foreign Contributions Regulation Act (FCRA)

Do they share the Gospel?

  • They made this comment on the review last year:
    • We certainly are Christian operated and run and it underlies all that we do. Sharing the Love of God and His word is paramount but we do it with the children & people we are working with and looking after, not out on the streets.’
  • Global Development Group is a secular organization.

What impact are they having?

  • No information found.

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

  • No financial information is published, so it is not possible to make this calculation.
  • Last year, they commented that
    • All admin costs etc are picked up by the Directors and any shortfall in monies received to what is expended are also picked up by the Directors.’

Do they pay their board members?

  • No constitution is publicly available to check.
  • No financial statements are publicly available to check.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • There is a PayPal-like button, but the next page is still ‘under construction’.

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

  • ‘I want to sponsor……(child / widow / couple / house mother / teacher)’

Is their reporting up-to-date?

  • No reporting by regulatory authorities is required.
  • 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.”  It’s not offered on the website, so just ask.

Does their reporting comply with the regulator’s requirements?

  • NA

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • NA

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

  • NA

Where were your (net) donations sent?

  • This is not disclosed.
  • The FCRA returns submitted to the Indian government show that approximately $27K was received by the charitable trust from IVCM in the year ended 31 March 2016, and $29K in the next year.

Who are the people controlling the organisation?

  • Three couples, described as ‘Our Directors’ are shown at the bottom here.
    • Alan Cockram
    • Judi Cockram
    • Dave Tunkin
    • Barb Tunkin
    • Don William
    • Joan William

To whom is IVCM accountable?

  • To Missions Interlink via its an Associate membership.
    • For one opinion on the strength of that accountability, see the section Activities in this review.
    • You might ask Missions Interlink whether it is acceptable for a member to be a charity yet not be registered with the ACNC.

Gateway Baptist Church: mini-charity review

Mini-charity review of Gateway Baptist Church (GBC), an organisation that seeks donations online, is an ‘Associated Organisation’ of Missions Interlink, and is accredited with the CMA Standards Council (a founding member). (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?

  • GBC has a ‘Complaints & Feedback Policy’, a requirement of its partnership with the CMA Standards Council. One of the ‘five key elements’ of this policy is ‘Principles’:
    • Our complaints and feedback system is modelled on biblical principles, including humility, fairness, accessibility, responsiveness, efficiency and integration.’
  • I sent them a draft of this review. Like last year, they…did not respond.

Is GBC registered?

  • As a charity, yes.
    • I can’t see a a ‘not-for-profit’ clause in the constitution. If this is the case, then this is unusual, and surprising. Every registered charity should have one, and it is an explicit requirement of the CMA Standards Council.
    • The registration is in the name Gateway Baptist Church Ltd because it is permitted to trade without ‘Limited/’Ltd’ at the end of its name.
    • Not to be confused with Gateway Baptist Church (GBC-old), the charity that was the church before GBC took it over. GBC’s first object in its constitution is
      • To incorporate and continue the ministry and activities of the unincorporated church known as Gateway Baptist Church ABN 25 025 137 207 and to take over its assets and undertakings on and from the date of incorporation hereof.
        • GBC was incorporated on 11 August 2015, but did not begin trading until 1 May 2016 (Directors’ report).
    • Also, not to be confused with Gateway Baptist Church And Community Centre.
      • Especially as GBC has a fund called the Gateway Community Fund (see below).
  • GBC has two other Australian wholly-owned subsidiaries:
    • the charity Bloom Asia Inc. (BAInc) (registered in 2012)
    • the charity Bloom Asia Ltd (BALtd) (registered in June 2016)
      • Because GBC still has not taken advantage of the ACNC’s group reporting concessions, these charities, and GBC-old, must report separately.
  • Other registrations:
    • As a public company, a company limited by guarantee.
    • Only one of the four charities holds a business name: BAInc has Bloom Creations Australia.
    • GBC does not have a fundraising licence in the state, per the ACNC Register, in which it operates[1].
    • BALtd: licensed to fundraise only in Queensland.
    • BAInc: no fundraising licences.
    • GBC-old: no fundraising licences.

What does it do?

  • GBC: other than obviously being a church, there’s no direct statement saying what it does; its activities are shown here.
  • GBC-old: replaced by GBC.
  • BAInc: no website; its Annual Information Statement 2016 (AIS 2016) says the same as last year: ‘As a Christian ministry aligned with Gateway Baptist Church, raised funds and awareness of charity work in Cambodia’.
    • There are no countries listed under ‘Where the Charity Operates’ on the ACNC Register.
  • BALtd: See here.

Do they share the Gospel?[2]

  • GBC: Yes
  • GBC-old: NA (replaced by GBC).
  • BAInc: No information available.
  • BALtd: No mention of the Gospel, Jesus or Christ on the website; tax deductibility (see below) would suggest that it doesn’t share the Gospel.

What impact are they having?

  • GBC:
    • Nothing systematic found. (The Directors’ Report, under ‘Key performance measures’, reports 40 baptisms.)
    • The terms of GBC’s accreditation with the CMA Standards Council require it to perform regular program evaluations. There is no mention of evaluation on the website.
  • GBC-old: No information found.
  • BAInc: No information found.
  • BALtd: No information found.

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

  • GBC: This is not disclosed, and the classification of the expenses does not permit an estimate.
  • GBC-old: Because it is a ‘basic religious charity’, no financial information has to be submitted to the ACNC.
  • BAInc: All expenses were classified as ‘Other expenses/payments’ in the AIS 2016 (no Financial Report 2016 required because of its size).
  • BALtd: Their ‘effective date’ of registration (on the ACNC Register) is 28 June 2016. With a 31 December year-end, the ACNC does not require such a charity to report until the following year.

Do they pay their board members?

  • The constitution does not prohibit such payments.
    • They are, however, prohibited under the terms of GBC’s accreditation with the CMA Standards Council [Standard 3.7].
  • Whether they were made is not disclosed.

Can you get a tax deduction?

  • GBC: No
  • GBC-old: NA (replaced by GBC).
  • BAInc: No
  • BALtd: No
  • Both GBC and BALtd are able to offer tax-deductibility for ‘Bloom’ because they are collecting for a project run by Global Development Group, a secular overseas aid and development organisation.
  • But nowhere is there an explanation for their ability to offer tax-deductibility for an entity that doesn’t even have an ABN, Gateway Community Fund.
    • This contravenes Standard 9.1 of the CMA Standards Council Standards.

Is their online giving secure?

  • GBC: Online giving is offered for five of the six choices. All five use PayPal, so yes, giving is secure.
  • GBC-old: NA
  • BAInc: NA – not offered.
  • BALtd: PayPal is used, so yes.

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

  • GBC:
    • General giving – Mackenzie campus’
    • ‘General giving – Ormeau Campus’
    • Gateway Beyond’
    • ‘Bloom (tax-deductible)’
    • ‘Gateway Community Fund (tax-deductible)’
    • ‘Call to Build Giving’ (not an online option)
  • GBC-old: NA
  • BAInc: No website
  • BALtd:
    • Donate (Without a Tax Receipt)’
    • ‘Donate (AUS – Recurring Gift) (tax-deductible)
    • ‘Donate (AUS – Single Gift) (tax-deductible)
    • ‘Donate (With Tax Receipt USA)’

Is their reporting up-to-date?

  • GBC: Yes (four and a half months after their year-end)
  • GBC-old: Yes (four and a half months after their year-end, a month earlier than last year).
  • BAInc: Yes (six months after their year-end, a week later than last year).
  • BALtd: Yes (none has been required yet).

Does their reporting comply with the regulator’s requirements?

  • GBC:
    • AIS 2016: No.
      • No activities or outcomes are disclosed.
      • ‘Other income’ does not match the financial statement.
      • Surely for a large church ‘Grants and donations…’ is not zero?
    • Financial Report 2016: Questionable
      • GBC acknowledge that GBC-old (the ‘Unincorporated Church’) and BALtd are wholly-owned subsidiaries (Not 16), so why aren’t they consolidated, i.e., included with the GBC figures?
      • Why no mention of the other subsidiary, BLInc?
      • Working capital – current assets less current liabilities – is negative by $235K, yet the directors make no comment on this threat to the going concern assumption.
      • ‘Building fund donations’ are just as much donations as the others. Classifying them as ‘Other income’ therefore understates revenue $403 K.
      • ‘Donation of assets from unincorporated church’ is, as they state elsewhere, part of revenue. It should therefore be included in revenue.
      • Similarly with ‘Finance income’.
      • Note 8 shows the entire net assets received from GBC-old as a non-cash item. How does this fit with the fact that $1.26 m cash is shown in the Statement of cash flows as ‘Donation of cash by unincorporated Church’?
      • A mixed classification of expenses is confusing. (That’s why it is not permitted.)
      • ‘Missions support expenses’, 21% of the total, is unexplained.
      • They say that the receipt of $20 m odd net assets from another entity during the year is a not a ‘significant change’ to GBC’s ‘state of affairs’ (paragraph 5 of the Directors’ Report). I disagree.
      • Having a line item ‘Operating expenses’, for 9% of the total, in a list of operating expenses, says nothing about the nature of that expense.
      • The product that was sold, generating $300K, is not disclosed.
      • The entire charity is a ministry, so what is ‘Ministry income’?
      • How was it that ‘Interest income’ was exactly $8K?
    • Even if the above issues don’t render the Financial Report non-compliant with ACNC’s requirement for ‘a true and fair view’, GBC’s partnership with the CMA Standards Council commits it to the transparency and accountability implied in 2 Corinthians 8:20, and that makes the issues relevant.
    • Because of the above issues, it is questionable whether GBC’s 2016 financial report is compliant with the CMA Standards Council Standards.
  • GBC-old:
    • AIS 2016: No.
      • Neither activities nor outcomes are disclosed.
      • It says that nothing will change in 2017, but if it doesn’t cease to exist it will be nothing like the organization it was up until May 2016.
    • Financial Report 2016: As a ‘basic religious charity’, they weren’t required to submit one. Nor include financial information in the AIS.
  • BAInc:
    • AIS 2016: Not quite – no outcomes are given, and the business name is missing.
    • Financial Report 2016: NA – none required (because of their small size).
  • BALtd:
    • AIS 2016: NA – because they only started in June 2016, not required yet.
    • Financial Report 2016: NA – as for the AIS.

What financial situation was shown in that Report?

  • GBC:
    • Working capital is negative. There is only 80 cents of current assets for every dollar of current liabilities.
    • Long-term financial structure, because of the land and buildings inherited from GBC-old, is sound.
  • GBC-old: NA
  • BAInc: NA. The AIS 2016 shows a surplus of $10K on $20K turnover, and assets and equity of $22K.
  • BALtd: NA

What did the auditor say about the last financial statements?

  • GBC:
    • The auditor, Daniel Gill, for Pilot Partners, gave a ‘clean’ opinion.
      • Not critical to the opinion, but relevant to your confidence in it:
        • He defines the information – ‘the other information’ – that he did not audit by reference to the ‘Company’s annual report’. But there is no annual report.
        • He incorrectly says that GBC’s reporting is defined by the Corporations Act 2001. It should be the ACNC Act.
    • Before you decide how much comfort to take from this opinion
      • Read the ‘Financial Report 2016’ section, above, and
      • Read about audit opinions here and here.
  • GBC-old: NA
  • BAInc: NA
  • BALtd: NA

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

  • GBC: No
    • No countries shown under ‘Where the Charity Operates’.
  • GBC-old: No
    • No countries shown under ‘Where the Charity Operates’.
    • ‘Phone’ and ‘Website’ are blank, but the ACNC says these are not compulsory.
  • BAInc: No
    • An ‘Entity Subtype’ has not been selected.
    • The business name is missing.
    • Email’, ‘Phone’, ‘Website’ are blank, but the ACNC says these are not compulsory.
  • BALtd: Almost – the Secretary has been included as a ‘responsible person’.

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • GBC:
    • The ‘Board of Elders’ is still not shown on the website, but
    • These are the people declared to be ‘responsible persons’ (on the ACNC Register):
      • David Angell
      • Paul Bakes
        • Is it this Paul Bakes?
      • Anne Cock
        • Is it this Anne Cock?
      • Megan Cocker
      • Jason Elsmore
      • Matthew Gray
      • Joshua Hanna
      • Derek Peters (a GBC executive)
      • Andrew Ross
      • Trevor Shinners
        • Is it this Trevor Shinners?
    • The board is responsible to the members. There were 590 members at 31 December 2016.
  • GBC-old:
    • Not shown on the GBC website.
    • The same people as for GBC are shown as ‘responsible persons’ (on the ACNC Register):
  • BAInc: From the ACNC Register:
    • David Angell (see above)
    • Derek Peters (see above)
    • Glenn Valentine
      • Is it this Glenn Valentine?
  • BALtd:

To whom is the charity accountable?

  • GBC:
    • As a charity, to the ACNC.
    • As an organisation accredited with them, to the CMA Standards Council.
    • To Missions Interlink via their Associate membership.
      • For one opinion on the strength of that accountability, see the section Activities in this review.
    • As a company, to ASIC.
  • GBC-old: To the Queensland associations regulator.
  • BAInc: To the ACNC and the Queensland associations regulator.
  • BALtd: To the ACNC, and to the companies’ regulator (ASIC).

 

  1. 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.
  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.