Archived: P4T Inc: mini charity review for donors

Mini charity review of P4T Inc (P4T) as an organisation that seeks donations^[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(For the situation last year, read the review here.)

Are they responsive to feedback?

• When sent a draft of this review, they responded by email:
  • ‘Thank you for your email. You will note we have made significant progress since we last corresponded, P4T Inc now having gained PBI status from the ACNC and DGR from the ATO. I make the following comments in relation to your draft report…
  • I responded but heard nothing more.
  • Both their comments and my responses have been included below.

Is P4T registered?

• As a charity, yes.
• Other registrations:
  • As a Victorian incorporated association (A0055403B).
  • P4T operates – according to the ACNC Register – in all states except the ACT. It is registered for fundraising [added 9.01.18] only in Victoria^[2].
  • If it’s ‘carrying on business’ outside Victoria, as it appears to be, then it doesn’t have the required registration (an ARBN).
    • Ministry response: ‘In regards to not having an ARBN, we take the view that P4T does not “carry on a business” outside Victoria. We do however, partner with Churches, organisations and people of goodwill across Australia whose values align with ours in that we want to see justice brought to the world by eradication of human trafficking. We choose to obtain fundraising licences in states where Pingpongathon events take place to err on the side of conservatism.’
      • Reviewer comment: P4T is principally in the business of raising money via the Pingpongathon.  These events occur outside Victoria.  Only if you say that these are not your events – and your website (and your practice of obtaining fundraising licences) certainly gives the impression that they are run in your name and controlled by you – would a reasonable person say that you are not ‘operating’ outside Victoria.  Especially as you declare on the ACNC Register that you operate interstate.
  • A Google search shows that P4T also uses the name ‘Partners for Transformation’. It is not a registered business name.

What do they do?

• From the AIS 2015:
  • P4T undertook a range of training activities in the Community Development (sic) space. It also again ran the Pingpongathon to raise awareness about Human (sic) trafficking and funds to assist in the fight against the impact of human trafficking.
    • This is almost identical to what was said in the AIS 2014.
    • There is no mention of training on the website.
• From ‘About’ on the website:
  • The Pong is a dynamic and fun twenty-four hour table tennis event that runs in venues across Australia every October. Participants sign up to play for a minimum of three hours of table tennis at their venue of choice and invite their family/friends to sponsor their efforts….In 2015, The Pong became a truly national event with venues in all Australian states. 1,500 participants at 41 venues raised $203,000.
    Venues included churches, schools, sporting clubs, open air community spaces & a local pub!
    While keeping the original vision of the Pong strong (engaging the hearts of boys and men as advocates on issues of trafficking and exploitation), The Pong opened up to the direct participation of girls and women for the first time.

Do they share the Gospel?

• No.

What impact are they having?

• No information found.

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

• It cost P4T $61K to make grants of $115K.
  • Some of the grants were made to Australian charities to whom you can donate directly:
    • Destiny Rescue
    • IJM Australia
  • Others are overseas, but I’m sure they’d be happy to receive your dollars too:
    • Dton Naam (US)
    • First Steps Cambodia (Cambodia)
    • The Hard Places Community (US)
    • Home of New Beginnings (Thailand)
    • Love 146 (US)
    • The Sold Project (US)
    • Urban Light – is it this one? (Thailand)

Can you get a tax deduction?

• Yes

Is their online giving secure?

• Security is not mentioned on the page where you enter your information (the second page)

Is their reporting up-to-date?

• Yes (lodged four months after their year-end).
  • 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 10 months ago.

Does their reporting comply with the regulator’s requirements?

• AIS 2015: Not quite. No outcomes are given.
• Financial Report 2015: No
  • Ministry response: ‘I’m not sure on what basis you make the assertion that “it is highly questionable that P4T would agree to provide a financial report tailored to your needs if you asked them for one”.  Most of our donors are either:  a. very small (donating amounts from $1 to $500 through having relationship with people participating in the Pingpongathon, who would not rely on our financial statements to make their donation), or  b. where we have a strong relationship, in which cases we provide whatever financial accountability that is required by that relationship.’
    • Reviewer response: The Accounting Standards are the basis for my comment.
  • Neither the Statement of Financial Performance nor the Movements in Equity financial statements comply with the Accounting Standards.
    • Ministry response: ‘Your interpretation of the Profit and Loss statement ignores the transfers to reserves. As our fundraising activities are held in the Sept to Nov period, some funds are carried over at Balance date in the reserves for both our beneficiary organisations, and as working capital to fund next year’s Pingpongathon costs through until the following September when the next round of fundraising events are held. The Net profit after transfers to reserves represents a better measure of what we are holding back…which is very little.’
      • Reviewer comment: My interpretation is based on the Accounting Standards.
  • The Notes of (sic) the Financial Statements are missing many Notes.
  • It is highly questionable that P4T would agree to provide a financial report tailored to your needs if you asked them for one.
  • The directors’ belief that P4T is not a reporting entity is therefore open to serious challenge.
    • Ministry response: ‘Since donor engagement is relational, we are of the view that Special Purpose reports are appropriate and cost effective for the size and nature of our organisation.’
      • Reviewer comment: ‘Relational donor engagement’ – unless you mean the willingness to provide tailored financial information – is not the criterion for special purpose reports. (Nor is cost effectiveness.)
  • There is no mention of related parties (an ACNC expectation).
  • The directors (again) don’t describe the financial reporting framework they have used, that is, how they chose the accounting policies.
    • Ministry response: Having turnover less than $250,000, P4T is not required to lodge its financial statements with the ACNC. The fact that we do so voluntarily is an indicator that we wish to be transparent with potential donors.

What financial situation was shown by that Report?

• Last year’s surplus, already healthy at 16% of income, was increased to 26%.
• No obvious concerns with the financial structure.

What did the auditor say about the last financial statements?

• He gave a ‘clean’ opinion. To take the right amount of comfort for this finding, please read here and here. But
  • In accepting the engagement, he has implicitly agreed with the directors’ decision to produce special purpose statements.
  • He has omitted one of the financial statements from the scope of his audit (and referred to two others by the wrong name).
  • See the points above under ‘Financial Report 2015’.

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

• Yes

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

• An unspecified number of ‘fundraisers’.

Who are the people controlling the organisation?

• Not shown on the website, but you can see who they have listed with the ACNC under ‘Responsible Persons’ here.
  • They are one short compared to what is required by their constitution.
    • Ministry response: [This] ‘is inaccurate. The constitution states the Association must have at least 5 members. Those 5 are listed as responsible persons with the ACNC.’
      • Reviewer comment: ‘The Constitution states that “Subject to section 23 of the Act, the committee shall consist of (a) the officers of the Association; and (b) two ordinary members.’ The previous section says that there are four ‘officers’.

To whom are P4T accountable?

• Not claimed on the website (or in the Financial Report), but P4T is a member of Missions Interlink, an organisation that has a general accountability regime^[3].
• They are also accountable to the ACNC.

1. Plus this request was sent in June 2015. ↑
2. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions. ↑
3. For one opinion on the strength of this accountability, see the section Activities in this review. ↑