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Care:  At least some of the information about this charity is no longer current.  Use the ‘Search charity names’ box to see if there is a later review.  If the latest review has a message like this, you are welcome to make your case for an updated review via email to ted@businessbythebook.com.au.

This is an updated review[1], principally for donors, of the Australian charity A21. Here is the request for donations.


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, and
  5. Find out more about how the charity says it uses donations.

Here’s the results for ‘A21’, with consideration also given to the essentials of the ACNC’s What should I consider when deciding which charity to support?[2]

Question 1

A search on the ACNC Register for ‘A21’ gives a registered charity in the name The A21 Campaign Limited.

Question 2

There is nothing to indicate that A21 uses either door-to-door or street collectors.

Question 3

The web address begins with a closed padlock symbol, so the website is secure [the ACNC article above]. But there is nothing about the security of your information on the giving pages.

Question 4

A21’s ABN record (via the ACNC Register) shows that your donation will entitle you to a tax deduction. But there is nothing about this on the donation pages[3].

Question 5


Don’t be misled by what A21 says on the ACNC Register. That describes what happened globally, not in Australia (which is where you are sending your donation)[4]. Here, instead, on the website, is what goes on in Australia:

Sharing the Gospel[5]


How A21 uses its revenue

The audited account of how donations are used is the Financial Report 2019 on the ACNC Register. The directors – most likely those shown below – signed a declaration [Financial Report 2019] that included this statement:

For this to be true the financial statements had to comply with the Australian Accounting Standards (AASs) [www.aasb.gov.au]. This means that, first up, the directors had to make the correct choice between the two types of financial statements, special purpose and general purpose. The distinction is important because less will have to be reported with special purpose statements. Special purpose financial statements are only appropriate when there are no users dependent on the other type. You, as one of these users are not dependent on general purpose statements if you can ring the A21 office and ‘command the preparation of (financial) reports tailored so as to satisfy specifically all of …[your] information needs’. If you can’t do this, then you are dependent on a regulator to specify the contents of A21’s financial report, that is, you are, contrary to what the A21 directors assert, dependent on general purpose reports. The directors of A21 [Financial Report 2019] said that there are no such users:

In its AIS 209, A21 said that it had six employees, 25 volunteers, and raised funds all over Australia and on the internet from donors totalling $1.76 million. It therefore stretches credulity to suggest that none of these users is dependent on the accounting regulator to get them the reports they need. The choice of special purpose statements was done with the agreement of their auditor, Kieran Gould for BDO East Coast Partnership. And he did this despite this advice from his professional body, Chartered Accountants Australia & New Zealand:

At the time of the decision, A21 had

  • Stakeholders all over Australia, at least in the hundreds, possible more [AIS 2019].
    • 10,984 followers of The A21 Campaign on Linked in (not just Australia).
  • Professional management [AIS 2019].
  • Almost 100% of its revenue coming from donors [Financial Report 2019].

Knowing this, how did the directors conclude that special purpose statements were appropriate? And then how did the auditor press on with the audit after he found out about this decision?

Other issues

1.  From the Financial Report 2019 it appears that AS21 is part of a group of companies:

But there is no group mentioned in Financial Report 2019. Via Nick Caine’s Linked in profile (see below), we see that it may be ‘Equip and Empower’:

A search on the ACNC Register gives this Australian registered charity: Equip and Empower Ministries Limited. The Register also shows that this charity is controlled by A21[6]. A21’s choice of special purpose statements means that A21 doesn’t have to consolidate the subsidiaries figures with its own. But it should at least mention the company’s existence. The statements choice also means that A21 does not have to disclose related parties. (Although not required legally, the ACNC has said that it expects all charities to make this disclosure.) 2.  There is insufficient disclosure of the expenses (see below). The combination of the choice of type of statements and the other issues above point to a false declaration of a true and fair view.

Who was responsible?

These are the two people who signed the Directors’ declaration [Financial Report 2019] on behalf of the Board on 10 May 2020:

Nicholas Caine

Kylie Dimauro

If there have been no changes to the Board since, and A21 has kept the ACNC Register up to date[7], these were the others on the Board at that time:

Darren Covington

Jeremy Horn

LoriAnn Vaughan-Biggers

Stephen Jeffs

Is it this Stephen Jeffs?

Stephen Powney

Nick Caine is the husband of Christine Caine, the (co-?) founder of A21[8]. The directors are responsible to the members. There is only one member:

No accountability here.

How much is sent overseas?

The Statement of profit or loss and other comprehensive income (with last year in the second column) [Financial Report 2019] should allow us to see how much was sent overseas (the rest being the cost of raising the money):

This shows that only 60% of the expenses were distributions to the trafficking work overseas. And then some of that may have gone to overheads (however defined).

Destination of the money sent

This is not disclosed. How does A21 ensure that the money sent overseas (a) reaches the intended recipient, and (b) is used for the purpose(s) for which it was given?

The other expenses

  • The $337 K was for five full-time equivalent employees.
  • ‘Auditors remunerations’ went up 43%, and ‘Administration costs’ 150%.


Everything A21 is doing may be being done ‘properly’[9], but unless the money is producing the change in people that the charity intends (i.e., an impact[10]), the money would be better used elsewhere. And the same applies if the impact is less than is being achieved by another charity. Nothing on the impact of the Australian work found. The US organisation’s Freedom Report 2019 also has nothing systematic on impact.

Charity response

A21 does not invite feedback (or complaints). We sent them a draft of this review. To the two email addresses on the ACNC Register. They did not respond.

  1. See here for the previous review.
  2. A section in the article, Donating and Volunteering:
    • 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?

  3. A very small print link in the footer confirms the tax deductibility.
  4. This description would be more reasonable if the bulk of the revenue went towards the overseas anti-trafficking work, but 40% stays here (and we suspect some of the 60% that is sent is consumed by overheads after arrival.)
  5. ‘When Helping Hurts by Brian Fikkert and Steve Corbett says this about sharing the Gospel: ‘A host of contextual issues determine the best manner and the appropriate time to present the gospel verbally, particularly in militant Muslim or Hindu settings. But without such a presentation, it is not possible for people to be personally transformed in all their relationships, which is what poverty alleviation is all about’ [Kindle Locations 1262-1264, Moody Publishers].
  6. The company is directed by four of A21’s directors.
  7. The Board is not shown on the website.
  8. If you are somebody who values faithfulness to an orthodox interpretation of Scripture, and uses that as one of your criteria when selecting recipients of your giving, I suggest you ‘google’ her.
  9. The behaviour of its people, its use of money, and how it goes about its business.
  10. The ACNC has previously – the Fact Sheet is no longer on the site – explained impact this way: “Every charity has a mission that is associated with producing a public benefit. As this mission is pursued, the changes produced in individuals and their communities can be referred to as the charity’s ‘impact.’ If you are donating to a charity, you may wish to make sure that your donation is creating the greatest impact possible.’ There is no reason why this wouldn’t still be their view.