This is review in the series ‘Australian Council for International Development (ACFID) Members’. ACFID ‘is the peak body for Australian non government (sic) organisations (NGOs) involved in international development and humanitarian action.’ It requires Members to adhere to a Code of Conduct.
GMP comment to the draft review:
“Some comments below.
The Audited Financial Statements do not carry the information that the Annual Report has and should be read together and not separately.”
- By law, the Financial Report must stand on its own; the directors have signed a declaration about the financial statements, not the financial statements and the annual report. So, no amount of information in an annual report can make up for a lack of information in the financial statements.
- Whatever is in the annual report, it cannot compensate for errors of accounting in the financial statements.
Covid-19 response: no update since 2020.
GMP comment: “Thank we will follow this up – it is not our website!”
Given what the ACFID does, ‘Global Mission Partners’ is probably a charity.
GMP comment: “and registered as such”
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”:
- Check the organisation’s name.
- Ask for identification from anyone seeking a donation.
- Be careful of online requests for donations.
- No tax deduction doesn’t mean the charity is not a legitimate one.
- Find out more about how the charity says it uses donations.
A search on the ACNC Register of charities for ‘Global Mission Partners’ gives this result:
This is one more in the list than in 2020. ‘Global Mission Partners Assist Limited’ has registered as a charity.
Which one is the ACFID member?
From the website address on each Register entry, it appears that the ACFID member is the third one.
GMP comment: “Correct”
‘Global Mission Partners’ is the name that Australian Churches of Christ Global Mission Partners Ltd (GMP) has recorded on the Register as an ‘Also known as’ name. (The name is a registered business name, along with a couple of others. Note, however, that ‘GMP’ is not registered.)
So, what are the other two charities above?
“Neither is a sub entity. Both Boards operate independently of the GMP Board – and cannot operate to the benefit of GMP. GMP cannot direct the boards to act to the benefit of GMP>”
Elsewhere in your response you say the opposite – that they are sub-entities. Whichever it is, GMP is the sole member of GMP Extend and GMP Assist, appoints the directors, and can pass a resolution.
“and overseas activities and also in support of Indigenous projects.”
Yes, this is consistent with the ‘Summary of activities’ on the ACNC Register, but not supported by the fact that you only have one entry under ‘Charity Programs: ‘Bushfire Appeal’.
It has no business names registered, so must trade under its full name.
GMP comment: “yes – of course”
We make this comment because there are many donors (and charities) that do not realise this.
GMP comment: “as it must”
No, there is nothing wrong with one charity collecting for another. It happens frequently.
The third charity, Global Mission Partners Assist Limited, is another public benevolent institution, established in late 2021. Although it is not mentioned on the GMP website (why is that?), information on the ACNC Register means that it is reasonable to conclude that it too is a wholly owned subsidiary of GMP. (Having registered it as a business name, it can trade under ‘GMP Assist’.)
“See above – it is a means of peoples supporting the redress costs of an entity that we never operated and not implying a legal responsibility for the redress matters in the past.”
What, then, is the relationship between this and the liability for redress in another charity, GMP?
But perhaps this is not the extent of the GMP group. From the website footer:
GMP has two of these four registered as a business name. Why not the other two?
Given the relationship between GMP Extend and GMP, and most likely GMP Assist, why is it that GMP still hasn’t taken advantage of the ACNC’s group reporting provision?
There is nothing to suggest from its website that GMP raises funds door-to-door or in public places.
GMP’s ‘Donate’ page has closed padlock at the beginning of the URL in the address bar, so the site is secure.
Although the page where you fill out your information has a bold ’Secure Checkout’ at the top, there is still no support for this claim.
The ABN record says that a tax deduction is only available for a donation to a fund operated by GMP, Churches of Christ Overseas Aid. The tax-deductible offering under ‘Give Now’ continues to make no reference to the fund, either on the first page or the second.
Question 5 The use of your donations
Vision, Mission and Values (and Principles)
Note the absence of ‘embody’.
“embody is a community education strategy and not a separate entity in itself and conducts no air or church prejects in its name.
The listing is of programs, not entities. ‘embody’ is a GMP program.
This location map shows how the above translates into projects. The filter ‘By type’ on this page still omits embody from the four types named above, but adds a new one, ‘Emergency appeal’.
Sharing the Gospel?
Not directly, but through some of the non-overseas aid partners, yes.
How the donations were used
One of the first things you might do with a financial report is to look at what the auditor said. In the case of GMP, you will see that they have continued their long-standing practice of giving a qualified audit opinion:
So, in the first sentence, the auditor, Graeme Rodda (for Moore Stephens), says that GMP ‘maintains effective internal controls over donations and other income raising activities’. Then he at once contradicts this, saying that ‘it is not practicable to maintain’ some of these controls.
The income raising that lacks controls is the income raising that is conducted by people other than GMP ‘staff or designated volunteers’.
These non-GMP people are not named. In their comment on an earlier review, GMP said that these people were ‘(church) congregations that take up offerings on our behalf’. But why would GMP need controls over this activity? To think so implies that it is a GMP fundraising activity, that it is GMP revenue while in the church’s hands. For this to be the case though, GMP would have to have control over these donations, an enforceable right to require the church to send the donations to GMP. But they wouldn’t even know that an offering had been taken, let alone how much had been given.
So, we continue to believe that this audit qualification is unwarranted.
Whether called for or not, why does GMP continue to be happy with a qualified audit report?
Not only is the qualification highly questionable, but so is what the auditor did because of not being able to audit the collections by third parties: he restricted his audit of all GMP fundraising activity, not just the church-based activity, to what had been entered into the books. Why?
Taking this as written means that you can take no comfort from the audit that the donations given to GMP were entered into the accounting records. This is a big gap.
“No need to add to what we have said in the past
For the benefit of readers, here’s what GMP last said (in 2017): “‘Most organisations you have reviewed do not have an ‘cash offering pattern’ as part of their external fundraising activities and please note that the gap is NOT in internal control see above. Following last year’s review we consulted with another Auditor in relation to the opinion on this matter and it confirms the appropriateness of this Audit qualification.’”
We have reviewed many charities that collect via churches. This shows that an audit qualification is avoidable. We stand by the solution we have given above.(As for it not being a gap in internal control, the clear words of the auditor contradict this.)
The financial statements: true and fair view?
The auditor signed that, apart from the above, the accounts showed a true and fair view and complied with the Accounting Standards. The directors, in their Directors’ Declaration, effectively said the same:
The evidence says that both statements are incorrect:
- Even though it controls two subsidiaries, GMP does not produce consolidated financial statements.
“GMP does not control the [two subsidiaries]… The other two are not subsidiaries – they are wholly owned sub entities.
Control? GMP is the sole member of GMP Extend, appoints the directors, and can pass any (legal) resolution it likes [GMP Extend constitution]. Subsidiary? By GMP Extend’s own description, yes, it is:
GMP has similar rights and powers under the GMP Assist constitution.
As charities in their own right, both GMP Extend and GMP Assist are required to report to the ACNC. If they were sub-entities, their figures would be, like the Overseas Aid Fund, be reported as part of GMP.
- Neither of the items included in the Statement of Profit or Loss and Other Comprehensive Income after ‘Surplus/deficit for the year should be shown there.
- The ‘Total comprehensive income/(loss) for the year is therefore materially incorrect.
- ‘Other Comprehensive Income is not shown.
- ‘Available for sale financial assets at fair value’ is the only disclosure for $5.00 million of assets.
- 58% of the expenses are in the item ‘Accountability and administration’ ($3.31 million), yet there is no further information given.
“Good levels of details are all in the full annual report and both need to be read together.”
Legally, no amount of information in an annual report can make up for a lack of information required in the financial statements for a true and fair view.
No, there is no further information on this item in the annual report.
- ‘Trusts, legacies & bequests’, ‘Grants’, and ‘Investment income’ are described as ‘Non-monetary donations and gifts’.
- The Statement of Changes in Equity is materially divergent from what the AASB 101 requires.
- There was a $836K increase in the Asset Revaluation Reserve yet there is no revaluation increase shown in the assets.
- The Statement of Cash Flows includes ‘Proceeds from reserves’, something that normally is a non-cash item.
- The audit report is unsigned.
“I will follow this up – the report on the GMP website is fully signed”
- The classification of programs does not match those for which donations are sought.
- Information is given for only three of the four programs (embody is missing).
- Note 2 (e) says that ‘Land and buildings are measured using the revaluation model’ but Note 7 says that they are ‘At cost’.
- Neither revenue nor expenses are named in the Statement of Profit or Loss and Other Comprehensive.
- The total of the expenses in the Statement of Profit or Loss and Other Comprehensive Income does not match the total in Note 16.
From the Directors’ Report [2021 Financial Report], these are the people who were responsible for the above situation:
Mark Riessen – an executive of Churches of Christ
The ACNC Register shows that Naomi Beames has replaced Bawden. (The current board is still not shown on the website.)
“The Board is referenced in the Annual Reports on the website and this gives details of the Board over time as well.”
The information can be kept up-to-date on the website; this is not the case with the annual report.
The use of your donations
Should you still be happy to consider a donation to GMP, let us look at where the donations went.
From the Statement of Cash Flows (with last year in the second column):
No further information is given on this figure, so we don’t have enough information to understand where the cash went.
Resources consumed (i.e., accrual)
This, from the Statement of Profit or Loss and Other Comprehensive Income, is how the activities translated into expenses (with last year in the second column):
There is no explanation of what is included in each of these items.
Note 17 (Notes to the Financial Statements) gives a breakup of the expenses for each of ‘ICP’, ‘COCOA’ and ‘IMA’ (the three programs named earlier).
There is no information given on the destination of the funds. The fact that GMP consider this information to be useful for donors is shown by the reporting of the country for most of the ‘Program’ funds and the name of the organisation for the ‘Associate Partners’ in the Annual Report 2020/21.
There is also no description, in the financial statements, of the measures taken to ensure that the funds (a) reach the intended local partner, and (b) are used for the purpose for which they were given.
GMP produce an ‘Impact Report’. However, this is merely an extract of some of the pages from the usual annual report, and that document contains no systematic study of impact as conventionally defined.
GMP welcomes feedback:
We sent GMP a draft of this review. They responded quickly. See at the beginning, and throughout. However, they did not respond to the second draft (the review as it appears now).
- See here for the previous review, two years ago. ↑
- 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]. ↑
- Given the relationship, why is there just one reference to ‘Global Missions Partners Extend’ on the GMP website? ↑
- ‘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]. ↑
- See, for example, paragraph 13, Guidance Statement GS 019 Auditing Fundraising Revenue of Not-for- Profit Entities, www.auasb.gov.au, and Example 7A in AASB 1058, www.aasb.gov.au ↑
- Now that GMP has appointed a new Executive Director, whose strengths include ‘impact measurement’, this may soon change: ↑