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International China Concern Ltd

This is a review in the series ‘Organisations accredited by the CMA Standards Council’.


The CMA Standards Council is ‘a ministry of Christian Ministry Advancement[1], with a missionto help build faith and trust in Christian organisations, be they churches, charities, schools or otherwise, to enable them to achieve more effective outcomes[2].


International China Concern Ltd’, was recently added[3] to the ‘Directory of Accredited Partners’[4].


It achieved this by meeting the Council’s ‘Principles and Standards of Responsible Stewardship’, and therefore is able to be promoted as an organisation that strives ‘to go beyond the basics in terms of good governance and good stewardship’.


The website linked from the Directory goes to a website in almost the same name , ‘International China Concern’. But it is not ICC’s website, but that of the parent organisation in Hong Kong.


This website seeks donations, including from Australians.



The charity regulator, 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 ‘International China Concern Ltd’ with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[5]

Question 1

A search on the ACNC Register of charities for ‘International China Concern Ltd’ gives a charity in that name, but with the addition of ‘(Australia)’ (ICC)[6].


Other registrations


ICC has registered two other names as business names, ICC Australia, and International China Concern.


ICC’s Facebook page, however, is in a name that is not registered.




ICC holds a fundraising licence in all states where one is required[7].

Question 2

Nothing in ICC’s public materials indicates that it uses either volunteer or professional door-to-door or street collectors.

Question 3

The website ICC refers people to has a ‘closed padlock symbol next to the website’s URL in the address bar’, so the website is secure [the first ACNC article above].


But there is no information on the first two pages of the donation process about the security of your information.

Question 4

‘Will my donation be tax deductible?’ on the charity’s ACNC Register record shows that a tax deduction is available. If you donate in Australian dollars, the website says the same.

Question 5: Where’s the money go?



ICC is a fundraiser for the overseas organisation called International China Concern (see the above website) [ACNC Register, Annual Information Statement (AIS) 2021, and Financial Report 2021].


Despite what it says on the Register and in its AIS 2021, it neither runs development programs overseas, nor directly benefits the people listed under ‘Who the charity helps’ on the ACNC Register.


Sharing the Gospel?[8]




Financial reporting


The audited account of how donations are used is the Financial Report on the ACNC Register.


The directors’ declaration about the statements


The directors signed a declaration [Directors’ Declaration, Financial Report 2021] that the financial statements

For this to be true, the directors must have chosen the correct type of financial statements. We don’t believe that they have.


The directors chose special purpose financial statements over general purpose. These are only relevant where all the users can ring ICC’s office and command the preparation of financial statements tailored to their needs. If they can’t do this, then the users are dependent on a regulator to specify the form and content of the financial statements. As users, you are then ‘potentially interested in the information provided in general purpose financial reports[9].


The requirements of special purpose statements are less onerous than those of general purpose. The two main omissions are consolidated financial statements and the disclosure of related parties and their transactions.


With revenue of $771K from multiple sources, professional management, 12 staff (AIS 2021), the receipt of government grants, and membership open to the public, the choice of special purpose statements is highly questionable. Which means the directors have made a highly questionable declaration.


Not something that one would expect from a charity given the stamp of high standards by the CMA Standards Council, the evangelical standards body[10].


The auditor, Neil S Harding, of Harding Martin, Chartered Accountants, agreed with the directors’ choice. This again is a highly questionable decision, both because of the argument given above, and this opinion of his professional body[11]:


Text Description automatically generated

Other issues

  • No explanation for the choice of special purpose statements.
  • No destination given for the ‘Donations’ of $150K (the second largest expense).
  • No source given for the ‘Administration reimbursement’ of $136K.

Who was responsible?


From the Directors’ Report [Financial Report 2021], these are the people responsible for the above reporting:

Ian Sigsworth

Claire Watson

Graham Young

Brian Tidmarsh

Dennis Brown-Kenyon

The ACNC Register shows that, since this time, Janet Conroy has replaced Claire Watson.


The directors are accountable to the members, but there are only five of them (down from seven last year). Even if none of the directors are members, which is unlikely, there is effectively little to no accountability here.


Where the donations went


These are the expenses over $10K (from the Statement of Profit or Loss and Other Comprehensive Income):

Payroll and on costs (sic) 483K

Donations 150K

Computer expenses 19K

Rent 14K

    • Employees cost 68% of the total.
    • ‘Donations’, only 21%, is presumably the money sent to China for projects. The recipient or recipients of this money are not identified, and ICC do not say how they ensure that this money gets to these recipients and that it is used for the purposes for which it was given.


Everything ICC is doing may be being done ‘properly’[12], but unless the money is producing the change in people that the charity intends (i.e., an impact), the money would be better used elsewhere. And the same applies if the impact is less than is being achieved by another charity.


As fundraiser, it can be argued that impact is money raised that would not otherwise have been raised, less the cost of raising it. ICC received ‘Donations’ of $594K, plus an ‘Administrative reimbursement’ of $136K, presumably from the ICC head office. From this, plus $40K from the government, they were able to send only $150K to China (Financial Report 2021). So, one way of looking at their impact is that they received $136K from the head office and sent it $150K. Another is to compare donations raised with donations sent: $594K versus $150K.


You’d have to ask whether you, as a donor, would be better off sending the money to China yourself.


Nothing on ICC’s impact could be found. (There is an Annual Report, but it is not for ICC. Not only this, but Australia is not mentioned.)


Standard 5.6 of the CMA Standards council standards (see above) requires regular program evaluations. Nothing by ICC on evaluations could be found.

Charity response

We sent a draft of this review to the charity. They…did not respond.



  1. Linked added by us.
  2. Emphasis in original.
  3. Text Description automatically generatedhttps://www.cmasc.net.au/news/presentation-of-certificates
  4. Having the list of accredited organisations on a site that is not secure is inconsistent with this building of ‘faith and trust’: Graphical user interface, text, application, chat or text message Description automatically generated
  5. A section in the article, Donating and Volunteering:
    1. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.
    2. Is it clear what the charity is trying to achieve and how its activities work towards its objectives?
    3. Would you like to spend your money, or time if volunteering, to support these objectives?
    4. Is the charity being transparent about its activities?

  6. Both ‘Inc’ and ‘Incorporated’ are acceptable under the Associations legislation.
  7. There is no mention of fundraising licences on the MMA website, nor in the Annual Report (there is no Financial Report).
  8. ‘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]
  9. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au.
  10. http://www.cmasc-generosity.net.au/directory.php:
  11. Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020.
  12. The behaviour of its people, its use of money, and how it goes about its business.