Archived: Dignity Freedom Network Australia Ltd: mini-charity review

Mini-charity review of Dignity Freedom Network Australia Ltd (DFN), an organisation that seeks donations online and is an Associate member^[1] 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.

Is it responsive to feedback?

• DFN claim to be ‘committed to accountability and transparency in all practices’.
• I sent them a draft of this review. Like last year, they…did not respond.

Is DFN registered?

• As a charity, yes.
• DFN is a public company, a company limited by guarantee.
• Its name:
  • They changed their name from Dalit Freedom Network Australia Ltd in October 2017^[2]. There is no explanation for this change either on the website or in the Financial Report 2017^[3].
  • DFN does not appear to have the provisions in its constitution necessary to permit it to omit ‘Ltd/Limited’ from the end of its name.
  • It does not have any business names registered^[4].
  • Because of the above, it does not have the necessary permissions to publicly use Dignity Freedom Network or Dignity Freedom Network Australia (its website), or DFN Australia and New Zealand (Facebook)^[5].
• In its AIS 2017 it said it intended to fundraise in four of the five states where, per the ACNC Register, it operates. All have a fundraising licensing regime for charities. The AIS 2017 also says that a licence is held in Victoria, but this does not agree with Victoria’s list. No licence is held in the other states. Perhaps the AIS 2017 information is a mistake, and DFN believes that it is exempt everywhere?
• DFN, per the ACNC Register, operates overseas only in India. But this is only in the sense that this is where your money is sent.

What do they do?

• Ignoring the fact that it combines Australia and New Zealand, the ‘Company Overview’ on Facebook gives the right picture^[6]:
  • We are the Aus/NZ branch of Dignity Freedom Network, a global not-for-profit organisation that works in India to end caste based (sic) discrimination.
    Here down under we work to raise awareness and advocate for India’s oppressed, while raising funds to support our sustainable development programs.
• What is the relationship with the New Zealand organization?
• DFA is a ‘Public Benevolent Institution’.

Do they share the Gospel?

• No
  • DFN have not selected ‘Advancing Religion’ as an ‘Entity Subtype’.

What impact are they having?

• There is no information on the website about impact (nor outcomes or results).

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

• ‘Aid and development’ projects is only 37% of expenses. ‘Employee benefits expense’ is larger at 44% of expenses.
• This seems quite different to what they claim on the website:
  • ‘14. Eighty percent of gifts received for a specific project are applied directly to that project and 20% towards administration. Eighty percent of sponsorship support is applied to the education program and 20% towards administration.’
• The implication that the cost of administration goes up proportionally – whatever the proportion – is a licence to make a profit on administration.

Do they pay their board members?

• The constitution does not prohibit this.
• The financial statements do not say one way or the other.

Can you get a tax deduction?

• Yes

Is their online giving secure?

• The ‘Donate’ page says ‘100% Secure’, but this claim is still not supported.

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

• It’s not clear. On the ‘Donate’ page you enter an amount etc. but there is no purpose specified. And a button underneath says ‘Sponsor a child’. But on the Home page, there is ‘Donate’, ‘Free a Child’, and ‘Free a Woman’. So, I’d say general purposes and sponsorship of either a woman or a child.

Where were your (net) donations sent?

• This is not disclosed.
• We know that they send the money to India, but without further information we can’t check the FCRA returns submitted to the Indian government.

Is their reporting up-to-date?

• Yes (five months after their year-end).

Does their reporting comply with the regulator’s requirements?

• AIS 2017: No
  • They don’t do the things they said they do here.
  • ‘Type of financial statement’ is incorrect.
  • Three of the five figures under ‘Gross Income’ are incorrect.
  • They are not registered as a fundraiser in Victoria.
• Financial Report 2017: No, not a true and fair view.
  • The audit report has been omitted from the Report.
  • There is no explanation of the relationship with the New Zealand organization.
    • Is it the reason for the unexplained $24K revenue item, ‘admin & management fees received’?
  • Special purpose financial statements, the ones that do not have to comply with all the Accounting Standards, are not appropriate for an organization seeking donations from the public, operating in five states, receiving more than half a million dollars in donations, and having a professional staff of five.
    • The directors do not say why they believe the entity to be ‘not a reporting entity’.
  • 98% of what is recorded as liabilities, $47K, are ‘Project funds unpaid’. Such funds are not normally liabilities.
  • A ‘Cost of sales’ of $184K makes no sense with ‘sale of goods’ of $1K, and zero inventory.
  • There is no mention of the change of name from ‘Dalit’ to ‘Dignity’.
  • The fact that the figures are not for the usual 12 months is mentioned only in one part of one Note.
  • The is no explanation for the existence of not insignificant ‘Finance costs’ when no money is owed.

What financial situation was shown in that Report?

• No obvious issues.

What did the auditor say about the last financial statements?

• There is an auditor – Kar Seng Chan of KSChan & Co – but no audit report.

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

• Almost – ‘Website’ is still blank. (The ACNC says that it is not compulsory.)

Who are the people controlling the organisation?

• Not shown on the website.
• From ‘Responsible Persons’ on the ACNC Register:
  • Jonathan Bradhurst
  • Catherine Rodwell
  • Jonathan Rodwell
  • William Saxton
• If the Rodwells are a couple, then with only two other directors, it would be valid for you to question the governance of this charity.

To whom is DFN accountable?

• They say, on the website, that
  • ‘12. To demonstrate our commitment to transparency and accountability, Dalit Freedom Network Australia posts a variety of information about the organisation on our website including: our financial statements and other related material.’
    • There are still no financial statements on the website.
• They are accountable, as a charity, to the ACNC.
• And to ASIC as a company.
• Their Associate membership of Missions Interlink means that they must comply with some standards.
  • For one opinion on the strength of that accountability, see the section Activities in this review.

1. Under its old name. ↑
2. There is also an incorporated association named Dalit Freedom Network Australia Inc. This entity has no ABN. Is it a forerunner of the superseded company name? ↑
3. Perhaps it is something to do with who the Dalits are, maybe even political? ↑
4. Dalit Freedom Network Australia Inc has the name Dalit Freedom Network registered. ↑
5. The New Zealand organization, Dignity Freedom Network New Zealand, is still not a registered charity. ↑
6. Both the ‘About’ page on the website, and the AIS 2017, combine what DFN does with what is done overseas by the organisations to whom it sends your money. ↑