Archived: International Gospel Centre Inc: mini-charity review

Mini charity review of International Gospel Centre Inc (IGC), an Associate member of Missions Link, and an organisation that asks you, online, to donate to it.

Is it responsive to feedback?

• When sent a draft of this review, they responded immediately, and with openness and humility. The ensuing conversation led to the correction of an error, a rephrasing, the comments you see throughout below, and this general comment:
  • Thank you for the opportunity to respond to your review. Your ministry is very important and we respond in the love of Jesus. Have made comment and/or correction under each applicable point you raise as necessary. Please let me know if there is anything else you require.

Is IGC registered?

• As a charity, yes.
• Incorporated as a South Australian incorporated association (A12906).
• Business names? None
  • Under the legislation (section 54) for this incorporation, IGC, because it doesn’t have any business names, must use its full name, including ‘Inc’ or ‘Incorporated’, on ‘every notice, advertisement, bill of exchange, receipt or other document given, published, drawn or issued by the association^[1].
    • Ministry comment: ‘International Gospel Centre Inc. uses our registered and official name to the best of our knowledge. We are ascertaining where this hasn’t occurred in the past and taking steps to ensure it does as we move forward. We’re also looking at a “trading as” name to allow us to use IGC- Compassion LOVE Action as an addition to International Gospel Centre Inc.’
    • It is arguable that, nowadays, this includes at least some of what is published on IGC’s social media pages.
      • Ministry comment: ‘IGC has sent a request to Facebook to change our Facebook name to International Gospel Centre.’
  • It also cannot trade under the names ‘IGC Foundation’ (YouTube)^[2], or ‘IGC’ (Facebook)^[3].
    • Ministry comment: ‘We are looking at all of our social media to ensure that not only are we removing confusion but ensuring there are no questions in regards to legality.’
• IGC says, on the ACNC Register, that it operates in all eight states.
  • It does not have the necessary ASIC registration (an ARBN).
    • Ministry comment: ‘We are incorporated under state law, we are on the ASIC register, and do not have offices in any other state except for SA. The use of the word “operate” is ambigious and we will make the necessary change on the ACNC Register.’
  • It has a fundraising licence in South Australia, New South Wales, Victoria and Western Australia. Perhaps it has assessed that one is not required in the other three states that have a licensing regime?^[4]
    • Ministry comment: ‘Our understanding is that we do not need a license in the other states and territories as we do not physically operate in these places. If we held an event in any of these places, we would require a license but I note the following: Qld is okay as we are registered through ACNC; Tas covered by SA license; ACT if donations are $15k per year or more; (and) NT is only required if we sell raffle tickets.

What do they do?

• ‘For more than 26 years, ‘International Gospel Centre’ has been committed to reaching the most destitute and vulnerable children in the Philippines, Uganda and Zambia by impacting their lives with the power of love in action – giving them hope for the future. We do this through comprehensive and effective programs that not only reach each child, but their families and their local and wider communities. Our largest program is Child Sponsorship where, for a small donation each month, sponsors provide children with basic health and education costs.’ [‘Who we are’]
• But they don’t do this themselves:
  • ‘Our mission partners with ‘IGC Foundation SE Asia’ in Cebu, Philippines, ‘ABC Children’s Aid’ in Uganda and ‘Grace Ministries’ in Zambia.
  • Partnerships?
    • The banner on the home page suggests that the relationship between IGC and the overseas organisations is considerably more than the usual partnership: it says ‘IGC International Gospel Centre Inc.’ ‘IGC Zambia’, ‘Philippines IGC Foundation SE Asia’, and ‘IGC Uganda’.
      • Ministry comment: ‘These partners operate from funds received from our fundraising activities. We are in the process of changing our web site to better reflect the partnership arrangements.’
    • There is no doubt that there is a strong relationship between IGC Foundation SEAsia Inc and IGC, but the IGC website does not make that relationship clear. In most places it presents them as two parts of an IGC whole, even interchangeably. For instance, both IGCs are described under ‘Our Team’.
      • The relationship between IGC Foundation SEAsia Inc, Pro Vision Kids and Christian Frontier Ministries is also not clear.
        • Ministry comment: ‘The relationship will be made clear in our new website and, as required, through our published materials. Agree that it is currently ambigious.’
        • Then there’s The Jesus Fellowship.
          • Ministry comment: ‘This is part of another organisation that works in conjunction with the Field Directors but is separate and should be separate on our website.’
      • There is no mention on the page for Uganda that it what is being talked about is the activities of a separate Ugandan organisation. And with the similar page for Zambia, it is not until half way through that it is apparent that the article was written by the partner (Grace Ministries Mission International).
        • Ministry comment: ‘New website being developed. This will also clearly define our partnership arrangement.’
      • IGC says, in a Note to the accounts, that it ‘ensures that funds are received and expended for designated purposes.’
        • Ministry comment: ‘Our partnership arrangements are very clear in this regard.’

Do they share the Gospel?

• NA. (Assuming that their partners are not actually ICG entities – see the discussion above – then they just collect money to fund their partners’ programs.)
  • Although IGC’s first ‘Entity Subtype’ on the ACNC Register is one that is consistent with sharing the Gospel, sharing the Gospel is not required by their constitution (under either ‘Purpose’ or ‘Objectives’).
• The partners: Yes, they do share the Gospel – at least the one in the Philippines does:
  • Ministry comment: ‘We are strengthening the relationship between us and our partners to truly reflect the fact that our foundation is in Jesus Christ. That is, our “business model” exists to enable the sharing of the Gospel. This is a carry over from the past and we will be very clear as we move forward and remove any ambiguity.’

What impact are they having?

• Nothing found.
  • Ministry comment: ‘This is a very important part of our public engagement and will be incorporated into the website we are developing.’

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

• Ministry comment: ‘These “costs” are donated “in kind” by a benefactor.’
• If we define ‘direct’ as ‘Overseas Mission Distributions’, then it cost $101K to send $278K (that is, 27%).
  

Can you get a tax deduction?

• Yes
  • But how does this fit with the fact that the Gospel is shared by at least one of the partners?
    • Ministry comment: ‘We are currently working through this.’

Is their online giving secure?

• PayPal is used, so yes.

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

• None

Is their reporting up-to-date?

• Yes (lodged seven months after their year-end, a week before the deadline).

Does their reporting comply with the regulator’s requirements?

• AIS 2016: No
  • IGC – Compassion LOVE Action is neither a business name nor a trading name.
  • No outcomes reported.
  • The figure for ‘Other Income’ does not match that in the Financial Report.
  • Ministry comment: ‘Thank you, we take this on notice.’
• Financial Report 2016:  Questionable
  • The choice of special purpose financial statements over normal statements, a choice that allows less than full compliance with the Accounting Standards, is, given the size and complexity of the charity, questionable.
    • The directors say that the financial statements ‘do not purport to be general purpose financial statements’, but they do not say what they are.
    • The directors don’t say why they didn’t produce general purpose financial statements.
  • The direct adjustment of equity, that is, not via the Statement of Comprehensive Income, of $45K (1.8 times the deficit), is said to be due to revised accounting policies and ‘other direct adjustments’. There is insufficient information disclosed about these changes. Has the applicable Accounting Standard been followed?
  • The ACNC Act, the legislation under which IGC reports, is not mentioned.
  • There is no disclosure of related parties (an ACNC expectation).
  • How is an office run without any non-current assets (including, for instance, office equipment)?
  • The distinction between direct and indirect income is not explained. Why would donations be direct but legacies – another form of donation – indirect?
  • The explanation for ‘Apostolic Ministry Expenses’, and the associated income, is guarded:
    • ‘Transactions described as Apostolic Ministry income and expenditure are made in various forms and include donations received, remuneration payments and benefits to a significant promoter of IGC. These payments are directly funded by donations in support of the Apostolic work of IGC together with direct ministry income that IGC derives from the Apostolic ministry within the organisation.’
      • There is no mention of any ‘apostolic’ activity on the website.
      • Remuneration should be included under Employee benefits expense.
      • If money is received on behalf of another ministry it should not be included in revenue.
      • Is it the money that is talked about by Cliff and Helen Beard on their site?
  • The name on the largest ‘mission distribution’, Cebu Missionary Foundation (Philippines) does not match the name of the partner elsewhere in the IGC material. (The name is nowhere on the website.)
  • Many of the Notes one would expect to see are missing.
    • Ministry comment: ‘Thank you, we take this on notice.’

What financial situation was shown in that Report?

• Last year’s surplus of 30% of income was dramatically reversed this year, to a negative 7%.
• Minimal liabilities – either current or non-current.
• No non-current assets.
• Salaries and wages $45K: this is for one part-time employee [AIS 2016].

What did the auditor say about the last financial statements?

• He said that ‘nothing has come to our attention that causes us to believe that the financial report…does not satisfy the requirements of (the ACNC Act)’. So not an audit, but the lesser assurance from a review^[5].

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

• Yes

Who are the people controlling the organisation?

• There is an undated photo of the ‘IGC Australia Board Members’ on the website, but no names.
• There are eleven people in the photo but only five on the ACNC Register:
  • Stephen Buck
    • Is it this Stephen Buck?
  • Michael Chant
  • Phil Pynor
  • Barry Scholz
  • Peter Steicke
    • Is it this Peter Steicke?
• Ministry comment: ‘Our board will be reflected on our new website.’

To whom is IGC accountable?

• To Missions Interlink[6] via their Associate membership.
• Also to the South Australian regulator of incorporated associations.
• And, as an Australian registered charity, to the ACNC.

1. The only exception is in the Regulations: For the purposes of section 54 of the Act, a chit or ticket evidencing the receipt by an association of an amount not exceeding $10 is prescribed as a receipt or document to which that section does not apply. ↑
2. Duplicated by, for instance, Investigator College. ↑
3. Duplicated by, for instance, a recent consultant of IGC. ↑
4. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions. ↑
5. As he says in his report, ‘A review…consists of making enquiries, primarily of persons responsible for financial and accounting matters, and applying analytical and other review procedures. A review is substantially less in scope than an audit…and consequently does not enable us to obtain assurance that we would become aware of all significant matters that might be identified in an audit.’ ↑
6. For one opinion on the strength of that accountability, see the section Activities in this review. ↑