Archived: Anglican Board of Mission – Australia Limited: mini charity review for donors

Mini charity review of Anglican Board of Mission – Australia Limited (ABM) as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

• In response to a draft of this review, the Executive Officer, Edwin Porter, sent his comments. After I replied he chose to respond to only one comment. He then authorised the publication of his reactions plus the following general comment:
  • ‘In a robust democracy it is good for organisations to be challenged and we welcome Ted Sherwood and others asking questions about what we do. In this review I would say that in a number of places Ted’s opinions differ from ours, as might be expected, and I leave it to the reader to come to their own conclusions or contact us directly. One point in particular I must mention is that Ted’s Table of Directorships is not an accurate reflection of the facts and I have expressed my disappointment to him at its inclusion. Thank you.’

Is ABM registered?

• As a charity, yes.
  • Not to be confused with the two charities with the name ‘Anglican Board of Mission’ but with the addition of ‘Auxiliary’ +. (See here, and here.)
  • Note 14 in the Annual Report says that ABM controls three other entities (and whose figures are included in the Financial Report 2016):
    • Anglican Board of Mission Australia Aboriginal Missions Special Purpose Trust Fund. This is an unincorporated entity that has not registered as a charity;
    • The Anglican Trust Fund for Development. This is a trading name of ABM, not a separate organisation;
      • Ministry response: The Executive Officer deleted ‘trading name of ABM’ and added ‘(a)n Overseas Aid Fund’.
        • Reviewer comment: ABM’s ABN record shows it as a trading name, and as recorded here.
    • ABM Benevolent Fund, a charity.
  • ABM has not taken advantage of the ACNC’s group reporting concessions. This means that each charity must submit an Annual Information Statement (AIS) and a Financial Report.
• Other registrations:
  • As a public company (097 944 717), a company limited by guarantee
    • The constitution appears to contain the provisions necessary to allow ABM to omit ‘Ltd/Limited’ at the end of its name.
    • It has two members, the Anglican Church of Australia and the Primate of that Church, without the possibility of any change to this membership (see Charity’s Document, below).
  • Neither of the other two names it uses, ABM and Anglican Board of Mission, are registered as business names.
  • ABM operates throughout Australia and has a request for donations on the internet. It doesn’t have a fundraising licence in any of the seven states that have a licensing regime. In one or more of these states this may be because it believes that it is exempt due to it being an arm of the Anglican Church of Australia^[1].

What does ABM do?

• See ‘Our Programs’ half way down here.
• How this translates into countries is shown here.

Does ABM share the Gospel?

• No
  • Ministry response: In two parts:
    • 1. He substituted ‘Yes’ and said that ‘There is always a debate about what it means to share the gospel.’
      • Reviewer comment:
        • I don’t think there’s much debate that ‘share the Gospel’ is referring to words not deeds.  See the first page of results from Googling ‘What does “share the Gospel” mean?’  There it is most often words, sometimes words plus deeds.
    • 2. ‘ABM takes its mandate from the New Testament, in particular Luke 4 18:19. This is well established in the Anglican Communion’s Marks of Mission and reflected in our programs. (see https://www.abmission.org/pages/-abms-five-marks-of-mission-56.html) In implementing this, ABM partners with Churches in many countries as we believe that the local church is best placed to reach local people with the gospel and so works to strengthen local churches, especially through strengthening local leadership. As John Deane says in the annual report;

ABM’s Church to Church program has also enhanced its support for the work of partners in the Pacific, South East Asia and Africa. Included in the activities are a number which focus on the nurture and spiritual development of children and leadership training for both clergy and lay. These types of programs are often very difficult for ABM’s Partners to fund but vitally necessary for growing churches. The Good Friday Gift remains well supported and health related activities have been a significant focus of the recent grants from this annual collection.

The Reconciliation Action Plan (RAP) to which ABM has committed itself continues to inform and guide much of the work with Aboriginal and Torres Strait Islander peoples. This

includes support for specific activities focused on the training of indigenous leaders and assisting the work of the National Aboriginal and Torres Strait Islander Anglican Council.

There is also encouragement and mentoring provided for dioceses and parishes as they seek to implement their own RAPs

Reviewer response: This appears to be ABM helping churches help their people be in a better position to share the Gospel, not ABM itself sharing the Gospel.

What impact are they having?

• Here is the report on the evaluations of program effectiveness performed in 2016. I’ll let you be the judge as to how well they answer the question of impact as defined by the ACNC.
• Same with the achievements described in the Annual Report 2015-2016.

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

• If we define ‘Funds to programs’ as the expenses ‘directly incurred…’, ABM incurred $2.82 m to invest $3.01 in beneficiaries.
  • This is ‘administration’ of 48%.
• Ministry response: In two parts:
  • 1. ‘This analysis is incorrect by a wide margin.’
    • Reviewer comment: I have been careful to give the assumptions behind the calculation; change the assumptions, and the result will change.
  • 2. ‘If you wish to focus on programs and calculate percentages then you need the context of the development focussed ACFID format annual report from the website. (http://www.youblisher.com/p/1646288-2015-16-ABM-Annual-Report/)   Attempting to use consolidated total corporate data from the statutory accounts and not the development specific data available in the annual report will prove meaningless for that purpose. ABM is much more than just a community development organisation and works with the Indigenous Australian community, the Anglican Church communion, undertakes advocacy on relevant issues, community education, and more. I won’t include the full text here but see page 10 of the annual report as an expanded answer. I also need to point out that it is an error to include Program Support costs and Community Education as “Administration” when they are certainly not of that nature.’
    • Reviewer comment:
      • The analysis is based on the information ABM provide and the explanation of ‘administration’ given by the ACNC; ABM don’t reference the ACFID format so it is not reasonable to expect a reader to go there instead of interpret what has been presented to the ACNC.

Can you get a tax deduction?

• The ABN record says yes.

Is ABM’s online giving secure?

• Industry standard encryption is used, so yes.

Is their reporting up-to-date?

• Yes (three months after their year-end – and two 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 six months in the past.

Does their reporting comply with the regulator’s requirements?

• AIS 2016: No
  • Ministry comment:
    • ‘Not sure how you can come to this conclusion. The ACNC would certainly advise us if we were not compliant.’
      • Reviewer response:
        • I came to this conclusion by comparing the AIS with the requirements for an AIS; the ACNC’s processes do not support the assertion that silence by the ACNC means compliance. It ‘conducts proportionate, risk-based monitoring of annual financial reports and Annual Information Statements as part of our compliance program.’
  • The ‘Financial Information’ is for the group, not ABM.
  • No outcomes are reported.
    • Ministry response: ‘There is a whole paragraph in the AIS of general outcomes listed and there are pages of specific outcomes in the detailed annual report.’
      • Reply sent by reviewer:
        • ABM report their purposes, not results. And the Annual Report is not included in the AIS 2016.
  • The business name is missing.
• Financial Report 2016: Yes
  • No information on the three subsidiaries, other than their name, is disclosed.
  • ‘Employee benefits expenses’ is not disclosed.
    • From the AIS 2015 we know that it is $1.72 m.
      • If part-time is 50% and casual 10% of full-time, this total represents average annual benefits of $93K.

What financial situation was shown by that Report?

• The surplus as a percentage of income decreased from 1% negative to 23% negative.
• ABN holds $9.70 m of investments not expected to be sold within the next 12 months. There is no explanation for how this fits with the mission. (There are no restricted reserves.)
  • Ministry comment:
    • ‘Approx. half, or $4.6m of ABM reserves are restricted.
    • Why are reserves crucial? Reserves allow programs to be funded to fair and equitable completion should donations vary or cease for some reason. This prevents a sudden and potentially harmful cessation of program. General reserves allow investment income to offset operating costs and allow for new initiatives.’
      • Reviewer response:
        • There are no restricted reserves disclosed in the financial statements; the explanation for the level of reserves should be in the financial statements (as the ACNC has recently recommended).
• ‘Funds to programs’ is 52% of expenses, but there is no explanation of to whom this money was sent and for what purpose.
  • Ministry comment: ‘There is a lengthy discussion of Programs and Projects in the annual report.’
    • Reviewer response: The Annual Report is neither lodged on the ACNC Register nor referenced in the financial statements.

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

• He gave a ‘clean’ opinion^[2].

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

• Apart from a missing business name, Anglicans in Development, yes.

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

• An extensive range. See the list next to ‘Projects’ here.

Who are the people controlling ABM?

• The people shown on the website here.
• The same list as under ‘Responsible Persons’ on the ACNC Register.
• To see all charity director positions in a particular name in Australia, search here.

Because of the possibility of two (or more) directors having the same name on the register of responsible persons, it is not possible to be definitive about the number of directorships held.

No. of charity directorships

• • Colin Bannerman 3
  • David Battrick 4
  • John Deane 3
  • Martin Drevikovsky 3
  • Claire Duffy 2
  • Stephen Harrison 6
  • Sarah MacNeil 10
  • Ian Morgan 2
  • Emma Riggs 4
  • John Roundhill 2
  • Debra Saffrey-Collins 2
  • Gregory Thompson 12
  • Garry Weatherill 3
  • Danielle Wuttke 2
• You may reasonably question how somebody can, especially if directorship is not their full-time occupation, successfully discharge their fiduciary responsibilities to more than a handful (?) of organisations. (And the ACNC Register only includes charities; the inclusion other not-for-profits and for-profit organisations may of course increase the above numbers.)
  • Ministry comment:
    • ‘Ted, I am really surprised to see your table (above) again this year as you know that much of the information presented is incorrect as I have previously informed you. It is a misuse of the ACNC data to enter a name into the ACNC database and then jump to the claim that all the organisations listed are related to one person, which is often nonsense. There are usually many people with the same name. When you look these names up on the ACNC to prepare your table you can see that often they are with obviously incompatible organisations and locations and yet you still include this table and then make disparaging comments about their ability to “successfully discharge fiduciary responsibilities”. If you are going to post data and make comments in the public domain then honesty is paramount and you have a very clear responsibility to ensure that you are not knowingly inaccurate, as such action could have negative implications for the people involved. The tiny footnote reference you include does nothing to offset the impression the table creates. [Editor: footnote elevated to the body] I informed you clearly last year that many of the ABM Directors listed here DO NOT have the number of personal Directorships that you list. The table is inaccurate and should not be part of your analysis.’
      • Reviewer comment:
        • The information merely reports the result of a search that the ACNC invites anybody to do.
        • I have made it clear that the ACNC search is on a name that is in the Register, and that because of the possibility of two or more directors having the same name on the Register, that it is not possible to be definitive about the number of directorships that, in this case, ABM directors have.
          • The ACNC gives no such warning.
        • I will leave it to the reader to judge what are ‘obviously incompatible organisations’ in the list produced from the ACNC search.
        • ABM, and all other charities, can easily change the name that is recorded on the Register to increase the chances that it will be unique.
        • Given the importance of the board to how a charity conducts itself, donors are entitled to question whether one of more of the charity’s directors might be overstretched.

To whom is ABM accountable?

• The Australian Council for International Development (ACFID). This is because it is a member, claimed in the website footer. Confirmed.
• ABM is accountable to the ACNC.

1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions. ↑
2. To take the right amount of comfort from a ‘clean opinion’, please read here and here. ↑