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Archived: Scripture Union Queensland: mini-charity review

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Mini-charity review of Scripture Union Queensland (SUQ), an organisation that seeks donations online, and is accredited with the CMA Standards Council[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

Is SUQ registered?

  • As a charity, yes.
    • It has a subsidiary, Body Corporate for Hope Central. No ABN could be found for this entity.
  • SUQ is a public company, a company limited by guarantee.
  • It has many business names.
    • None are disclosed on the ACNC Register.
    • Only one, School Chaplaincy A.C.T., is disclosed on Australian Business Register.
  • Although it is permitted to omit ‘Limited/Ltd’ at the end of its name, it has no licence to trade under other than Scripture Union Queensland. The website and its social media pages contravene this.
  • It has no trademarks.
  • SUQ operates in Australia, per the ACNC Register, in Queensland and the Australian Capital Territory. It seeks donations on the internet, both on its own site, and on others (Good Company, Pro Bono Australia, Everyday Hero, and others?)
    • Whether or not it uses street collectors is not disclosed.
    • It only has a fundraising licence Queensland. There are five other states that have a licensing regime applicable to charities. SUQ doesn’t explain why they have only one licence.
  • SUQ, per the ACNC Register, does not operate overseas.

What do they do?

Does SUQ share the Gospel?[4]

  • Yes – but they are not meant to in the Chaplaincy program:

  • In the three years to 2013, complaints of proselytising were few:
    • The national rate is 13 complaints of proselytising per annum (three year average). With 2,900 schools having chaplains, the rate of proselytising complaints is 0.4 per cent per annum, and has been declining year on year. In 2013, there was one complaint nationally[5].
  • SUQ is required, by its accreditation with the CMA Standards Council (Standard 1.2) to have a statement of faith. There isn’t one on the website, nor is there a ‘What we believe’ section.

What impact are they having?

  • Nothing systematic found.
  • Standard 5.6 of the CMA Standards Council standards (see above) requires that regular program evaluations must be performed. There is no mention of these on the website.

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

  • SUQ says that 84% goes to ‘Programs’. By deduction this is ‘Chaplaincy expenses’ and the undefined ‘Ministry expenses’. The Financial Report 2016 does not have a sufficient level of disclosure to say whether there is any ‘administration’ in these two expenses.

Do they pay their board members?

  • The SUQ governing document does not permit this.
  • Note 10 says that they are not paid.
  • Expenses are not disclosed at a level that allows one to check for a payment.

Can you get a tax deduction?

  • The ABN record shows that you can claim a tax deduction for a donation both to SUQ and to its fund, Scripture Union Queensland Schools Ministry Fund.
    • The ‘Choose where my gift goes’ page, however, distinguishes between those causes that are ‘tax-deductible’ and those that aren’t.

Is their online giving secure?

  • They say, below the fold on the ‘Donate’ page, that ‘Your credit card details are never stored with us. They are sent straight to our payment processor over a highly secure connection.’ The name of the provider is not given.

Is their reporting up-to-date?

  • Yes (lodged four and a half months after their year-end, two months later than last year).
    • 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 over 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • The financial information is for the group, not SUQ.
    • It incorrectly says that there is no consolidation of entities.
    • ‘Other Income…’ and ‘Employee expenses’ are incorrect.
    • The business names are omitted.
    • Outcomes are not mentioned.
    • Is it really the case that there are exactly 500 full time and 200 part time employees?
  • Financial Report 2016[6]: Yes.
    • But SUQ is ‘transparent and accountable to its stakeholders’, so here’s some changes that would result in a clearer picture of performance and position:
      • Disclose basic information on the subsidiary, Body Corporate for Hope Central [Note 19].
      • There is no other mention of this entity in the Financial Report, nor on the website.
      • There are only two incidental mentions of ‘Hope Central’ on the website. (A Google search reveals that it is the name of the building they occupy in Brisbane.)
      • Why no ABN?
      • This entity has negative equity (Note 20)?
      • Include all the disclosures required by the Accounting Standards for the Consolidated Statement of Comprehensive Income.
      • Likewise, the Consolidated Statement of Changes in Equity.
      • Separate ‘Other income’ from ‘Revenue’.
      • Although ‘Other income’ is only 4% of revenue, it would be interesting to know what is included in this $1.41 m.
      • Disclose fundraising expenses.
      • Use one of the two expense classifications allowed by the Accounting Standards, not a mixed classification.
      • Explain the major expenses, including ‘Marketing expenses’ and ‘Ministry expenses’ (the entire charity, as a ‘Christian’ charity, is a ‘ministry’.)
      • Disclose information about related parties. (There is only a Note on ‘Controlled entities’.
      • For instance, what is the relationship between SUQ and Scripture Union Australia? (it owes $145K).
      • Distinguish between ‘Objectives’ and ‘Principal activities’ in the Directors’ Report (and report on both).
      • Give a breakup of ‘Ministry Reserves’ (so that donors + know the purpose of retaining some of the profits for the future).
      • The fact that they can ‘appropriately manage and track chaplaincy and other ministry reserves internally’ is not relevant to a decision about whether to disclose information to stakeholders – external reporting should not be a management tool for an organisation of SUQ’s size and complexity.
      • It would be helpful if we knew how many ‘key management personnel’ shared the $619K.
      • Remove ‘Workers compensation insurance’ from the figure for employee benefits [Note 3].
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore Arrow is not complying with Standard 6.1 of the CMA Standards Council standards (see above).

What financial situation was shown by that Report?

  • Surplus as a percentage of revenue increased from negative 10% to a little over zero positive.
  • ‘Cash and cash equivalents’ represents approximately two months of revenue.
  • Employee benefits was 77% of expenses.
  • Current assets as a multiple of current liabilities (working capital) was maintained at a positive 1.8.
  • With only $744K of non-current liabilities, long-term financial structure is, based on this report, sound.

What did the auditor say about the last financial statements?

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

  • No[7]
    • It is long overdue in selecting an ‘Entity Subtype’.
    • ‘Other Name(s)’ is missing the 11 business names.

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

  • ‘Where it’s most needed’
  • Two long lists under ‘Choose where my gift goes’, one for tax deductible projects the other for non-tax-deductible projects.

Where were your (net) donations sent?

  • There is no disclosure beyond ‘Chaplaincy expenses’ ($22.70 m) and ‘Ministry expenses’ ($4.68 m).

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) has two additional names, Sally-Ann Davis and Storme Vunderink:
  • There are eight (8) charities with a Ruth Limkin as a board member. Her LinkedIn profile says that she is also a director of Christian Super and, although not shown as a responsible person, Northside Christian College. So that’s at least ten directorships.
    • Seven of them belong to Bible Society Australia. (The only member of the Bible Society Australia_ACNC Group for which she is not a board member is Centre for Public Christianity.)
    • But the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.
    • Therefore, if after eliminating the charities for which SUQ’s Ruth Limkin is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether her ability to discharge her fiduciary responsibilities is threatened.
  • The quorum for a board meeting does not meet the requirements of SUQ’s accreditation with the CMA Standards Council (Standards 3.2, 3.3).
  • The Board is responsible to the membership. When last disclosed (30 June 2016, Directors’ Report), there were 94 members.

To whom are SUQ accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means SUQ’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • SUQ has gone beyond the charity tick, and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – see the website footer. For this is must abide by the Council’s  Principles and Standards of Responsible Stewardship.
  • SUQ is also accountable, as a company, to ASIC.



  1. SUQ is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. I agree with Randy Alcorn [Money, Possessions, & Eternity, Tyndale, 2003] when he says that ‘Any Christian leaders who resist financial accountability make themselves suspect.’ [page 425].
  3. This is a contravention of, if not the letter then certainly the spirit, Standard 8.7 of the CMA Standards Council Standards.
  4. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  5. This is the footnote to that quote: ‘These are government figures supplied at the Senate estimates hearing on 4 June 2014, reported at http://www.theguardian.com/world/2014/jun/09/ complaints-about-school-chaplaincy-programme-on-the-decline-fi gures-show (accessed 14 June 2014).’
  6. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.
  7. This means that SUQ is contravening Standard 2.4 of the CMA Standards Council Standards.