Archived: SIM Australia, charity review

This is a charity review, a review, for supporters and potential supporters, of the Australian charity Sim Australia (SIM).

It is structured according to the charity’s entry on the ACNC[i]Register, and its purpose is to supply some information extra to what is there, information that may be helpful in your giving decision.

It is up to you to decide whether any or all of the information presented here is what you need in order to make that decision, and whether you should seek any other information, either from the charity itself or from other sources.

Ministry response

Prior to publishing this review, I sent my observations to the charity, on 16 November 2015, and invited them to comment. They did not reply.

Organisation of this review

• The first part of this review is organised according to the headings in the register entry. This is how to use this section of the review:
  1. For each heading in the register entry, first read the information under that heading.
  2. Then check if that heading is included below. (Headings for which there is no comment are not included.)
• There is then a more detailed comment on the Financial Report.
• Lastly, there is a section Membership of accountability organisations claimed.

Sources

• ACNC Register (including links)
• Google search on the charity’s names (see Charity Details, below).
• SIM website. SIM social media sites, just before the footer here. Plus SIM on LinkedIn.
• State government fundraising licence registers.
• www.glassdoor.com

REGISTRATION DETAILS

Entity Subtype

• A type consistent with sharing the Gospel.
• The company’s prime object in its constitution is also consistent with sharing the Gospel:

Motivated by Christian faith in God and Jesus Christ as set out in the bible, the objects of the Company are to glorify God by planting, strengthening, and partnering with churches around the world, as we evangelise the unreached, minister to human need, disciple believers into churches and equip churches to fulfil Christ’s Commission…

CHARITY DETAILS

Legal Name

• Not to be confused with another charity, Simaid Trust, a trust controlled by SIM, and consolidated with SIM in the financial statements below.
  • Although Simaid’s four financial statements, in abbreviated form, are included in SIM’s financial statements as Notes, Simaid has not lodged its financial statements with the ACNC as required.
• SIM is a public company, a company limited by guarantee.
• It is permitted to omit ‘Ltd’ on the end of its name.
• Also consolidated are two other companies: International Christian Fellowship and Africa Evangelical Fellowship. Said to be ‘dormant’, no explanation is given why they remain registered 26 and 17 years after being taken over.

Charity ABN

• Tax deductibility: You cannot claim a tax deduction for a donation to SIM. (Although you can for one to Simaid Trust.)

Charity Street Address

• The postal address, from the website: PO Box 42, Penshurst NSW 2222.

Email

• Blank. Try, from the website, sending.director@sim.org.au.

ANNUAL REPORTING

• AIS 2014

• This is SIM’s compulsory Annual Information Statement 2014 (AIS 2014).
• It gives basic financial information.
• If you think that this is sufficient for you then you should note that
  • ‘Employee expenses’ is ‘Other Staff’ in the Income Statement. There is also $1.88 m of Missionary Salaries & Taxes, and $712K of Missionary Housing.

• Financial Report 2014

• The report was signed two and a half months after the year end.
• It was then lodged three months after that.
• The coverage of finances in this review is left until the financial report proper (see Latest financial report – detail, below).

ABOUT THE CHARITY

• Statement of Faith
  • Here.
  • But there isn’t one in the Constitution (see Charity’s Document (sic), below).

Date Established

• Here’s a history of the broader SIM organisation.

Who the Charity Benefits

• Vision
  • None found.
• Mission
  • SIM’s ‘purpose’ is here.
• Activities (What did SIM do?)
  • From Description of charity’s activities and outcomes in the AIS 2014:
    • SIM Australia has been empowered by God to facilitate people, prayer and funds for Christ’s global mission.
    • For some examples of the what was done with these resources, see the annual report, The SIM Effect.
• Outcomes (What did SIM deliver?)
  • From Description of charity’s activities and outcomes in the AIS 2014:
    • Praise God that SIM continues to grow in this period, with 10 new members, 41 associates, 5 teams and 119 active missionaries (as at 30Sep14), serving in 30 countries. Each person who serves in Australia results in more churches, people and prayer for His mission.
      • Unfortunately this doesn’t distinguish growth in numbers from the position at year end, so we can’t tell whether or not SIM increased the number of ‘associates’, ‘teams’, ‘active missionaries’, and countries this year. (And whether, therefore, there were ‘more churches, people and prayer’.)
        • However, from last year’s AIS, we can calculate that this year the number of missionaries increased by six, the number of countries increased by five, and the number of teams remained the same. None of the other indicators were reported last year.
      • Nowhere is the term ‘associates’ explained.
      • Nor is ‘member’.
      • How is an inactive missionary still a missionary?
      • For a few examples of what these people delivered, see the annual report, The SIM Effect.
• Impact (How were people’s lives improved?)
  • Nothing systematic found.
  • There are a few anecdotal accounts in the annual report, The SIM Effect

Financial Year End

• This means that the next financial report is due by 31 March 2016. Before that the financial information on the Register will be up to 18 months out-of-date.

WHERE THE CHARITY OPERATES

Operating State(s)[ii]

• Here’s the details for the representatives for each state.
  • And a page of its own for Vic/Tas.

Size of Charity

• With a revenue of $7.03 m, SIM easily qualifies in the largest of the ACNC three size categories (‘Large’).

CHARITY’S DOCUMENT (SIC)

• There is no Annual Report/Review available on the ACNC Register.
• But it is available on the SIM website.

RESPONSIBLE PERSONS

No. of Australian charity directorships[iii]

Jonathan Cheung                                   2

Stephen Early                                          2

Alyson Hicks                                           2

Christopher Seddon                              4

Russell Ricketts                                      3

Michael Gordon                                    12

Robert Cole                                             6

Amelia Antognelli                                  2

• Robert Cole is missing from Our Board on the website. Maybe this is because he is the Secretary, not a member of the Board, and therefore incorrectly listed on the ACNC Register?
• No reason was found for the ‘Positions’ to vary between ‘Board Member’, ‘Director’, and ‘Other’. 

(End of review of the ACNC Register information)

Latest financial report – detail

• The declaration required by the NSW Charitable Fundraising Authority Conditions has not been included.

Directors’ Report (page 2 of the Financial Report)

• No such report is required by the ACNC.
• The qualifications, experience, and special responsibilities are not given for each of the directors.
• ‘Performance measures’ is missing, the Secretary is not identified, Committee meetings are missing from ‘Meeting (sic) of Directors’, and ‘Review and Results of Operations’ is not required.
• The company has 14 members, the same as last year. There are 13 directors, all of whom have to be members. Have all but one of the past directors resigned membership?

A letter from the auditors about their independence – page 6 of the Financial Report

• The ACNC does not require this to be lodged.

An independent opinion on the financial statements – the Independent Auditor’s Report (the ninth page of the Financial Report)

• Reports by Australian NFPs that follow the Australian Accounting Standards are unlikely to comply with International Financial Reporting Standards. The auditor’s opinion here that they do comply is therefore unusual.
• Whatever day in November the auditor signed his report – this information is missing – the directors’ signature a month later means that his signature was premature.
• This is a ‘clean’ opinion.  Read here and here to draw the right conclusions from this.

What’s left at the end of the year – the Balance Sheet (page 11 of the Financial Report

• Cash $1.32 M (including Note 4)
  • This should be ‘Cash and cash equivalents’.
  • There is no explanation for why this large an amount is held, and particularly why there is $1.27 m in ‘Current Accounts’.
  • When the tax deductible money belonging to Simaid has to be kept separate, why is the balance zero?

• Receivables $93K (including Note 5)
  • This includes assets that are normally in a group of their own.
  • Are any of these amounts of doubtful collectability?

• Investments $5.13 M (current) plus $1.07 m (non-current) (including Note 6)
  • There is no explanation for why so much has been invested.
  • If any of the term deposits are for three months or less they should have been included in ‘Cash and cash equivalents’ (see above), not here.
  • This presentation matches neither the Accounting Standards nor the policy described in Note 1.
  • Why is ‘Staff Housing Loan’ an investment, but ‘Staff Car Loans – Unsecured’ a receivable?
    • Why are there no repayments due on the housing loan in the next 12 months?

• Property, Plant & Equipment $2.05 m (including Note 7)
  • Freehold Land & Buildings $1.86 m
    • This class appears to use neither of the two permitted valuation models consistently.
    • Why are four of the five properties not depreciated?
  • Furniture & Equipment / Motor Vehicles: the deduction is not a provision.
  • Intangible Assets
    • These are not properly part of Property, Plant and Equipment.
  • There is no reconciliation of written down values.

• Bank Overdraft $54K (including Note 8)
  • Note 8 explains Payables of $566K, not just bank overdraft.
  • There is no explanation why, with so much money in the bank, there is the need for the expense of an overdraft.

• Provisions $40K (current) plus $27K (non-current) (including Note 9)
  • These are all employee benefits.

• Payables $511K (including Note 8)
  • There is no explanation for the bulk of this total: ‘Missionary Personal Accounts’ and ‘Missionary Fringe Benefits’.
  • Normally titled ‘Trade and other payables’.

• Loans $148K (including Note 10)
  • There is no explanation for an increasing amount owed not earning interest and not secured.
    • Why is this all repayable beyond 12 months?

• Accumulated Funds & Reserves $8.89 m
  • There is no Note explaining this amount.

What was earned, what was consumed during the year – the Income Statement (page 12 of the Financial Report)

• The title of this statement does not comply with the Accounting Standards.
• The format is long out-of-date.
  • ‘Other comprehensive income’ is missing.
• There are no Notes to explain the material items.

Where the money came from

• No ‘Other income’ or dividends?
• Local Gifts & Donations $5.72 m
  • Despite there being a choice between ‘SIM Australia’, ‘Projects’, and ‘Missionaries’ on the website, and then two, 62, and 113 options respectively under each of those, there is no further disclosure of the intended destination of these donations.
  • There is no separate total for the Overseas Aid Fund.

• Overseas Gifts & Donations $817K
  • There is no explanation of this item.

• Local Legacies & Bequests $136K
  • None from overseas?

Where the money went to

• SIM says that it ‘aims to ensure that 85% of each dollar donated is directed to the field’, but because ‘field’ is not defined, we can’t check this figure.
  • Even if we assume that ‘field’ means ‘sent overseas’, there is still insufficient information.
• The expenses classification is a mixture of the two permitted methods.
• The following expenses have not been disclosed:

• Employee benefits expense
• Superannuation expense
• Finance expense
• Cost of sales
• Fundraising

• In which of the line items below are the bequests sent to SIM International (see Note 3)?
• Missionary Salaries & Taxes $1.88 m
• Missionary Housing $712K
• Missionary Other Expenses $1.08 m
  • Given that the missionaries are not employed by SIM, why is it paying over 55% of money raised for missionaries and their support
• Ministry Fund Expenses $445K
  • There is no explanation of this item.
• Project Expenses $1.30 m
  • There is no explanation of this item. Is it money sent to partners overseas or expenses incurred by SIM itself overseas?
• Personnel Expenses – Other Staff $550K
  • This implies that the missionaries, above, are ‘staff’. Why then report this figure as ‘Employee expenses’ in the AIS 2014 (see above)?
  • Based on the number of employees shown in their AIS 2014, and assuming that all six part-time employees work 2/3 time, and ignoring the casual wages, this represents an average expense per employee of only $29K.
• Depreciation – Included in Admin Expenses $50K
  • If this is included in ‘Admin Expenses’ then including it here is double-counting.
• Administration Expense $305K
  • This represents 4.3% of Revenue.
    • However, some expenses that many other charities would include under ‘administration’ appear separately.
• Promotion & Fundraising Expense $260K
• Community Education Expense $260K
  • No explanation is given for the unusual result of two separate items having exactly the same total at the end of the year. And for the second year in a row.
    • Is it because it is not actual expenses that are recorded, but an arbitrary allocation?

Where the cash came from and went to – the Statement of Cash Flows (page 13 of the Financial Report)

• Cash Flow From Operating Activities
  • No sales, bequests or dividends?
  • Why is the cash from interest identical to the amount earned
• Cash flows (sic) used in Financing Activities
  • Why are ‘Missionary Personal Funds’ included under ‘financing’?
  • The ‘Closing Balance’ does not match (by a long way) the amount for ‘Cash’ in the Balance Sheet.

Movements in the net wealth of the charity – the Statement of Changes in Equity – page 14 of the Financial Report

• This statement diverges markedly from what is required by the Accounting Standards.

Essential information to go with the figures – the Notes to the Financial Statements – page 15 of the financial report

Note 1   Reporting Entity

• From the description here, it is more likely that SIM acquired these other two missionary companies, not merged with them.

 Note 2   Basis of Preparation

• For a NFP, like SIM, that followed the Australian Accounting Standards, it is unlikely that their statements are compliant with the International Financial Reporting Standards.

 Note 3   Statement of Significant Accounting Policies

• Basis of Consolidation
  • The policy on inter-company transactions and balances is missing.
• Revenue
  • The ‘cash basis’ is not a revenue recognition basis.
  • The solicitation for bequests on the website does not mention the possible transfer to SIM International.
  • Interest is not mentioned.
• Depreciation
  • The heading should be ‘Property, plant and equipment’.
  • ‘Deemed cost’ is only relevant where the item is not actually purchased, which is unlikely to be the case for all these properties.
  • No policy is disclosed on the review of the figures or on derecognition.
• Missing Notes:
  • Cash and cash equivalents
  • Trade and other receivables
  • Impairment of non-financial assets
  • Trade and other payables
  • Intangibles
  • Fair value measurement
  • New, revised or amending Accounting Standards and Interpretations adopted
  • Goods and Services Tax (‘GST’) and other similar taxes
  • New Accounting Standards and Interpretations not yet mandatory or early adopted
  • Critical accounting judgements, estimates and assumptions

Note 13   Foreign Currency

• There is no explanation for the existence of a bank account for Simaid in US dollars. Or why an overdraft is needed for that account.

 Notes 14-17   SIMaid

• Because SIMaid has not lodged its accounts with the ACNC as required, it is not possible to confirm these figures.

 Note 18   Related Party Disclosures

• Note 18a Remuneration of Directors
  • When the Constitution says that ‘The Directors must not be paid any remuneration for their services as Directors’, how were these payments possible?

• Note 18c Loans to Directors and Executives
  • Presumably this disclosure doesn’t match the figures in the balance sheet because some of the loans there are not to ‘executives’.

• Note 18d Transactions with SIM International and other SIM Field Offices
  • How is Australia a ‘field office’?
  • The relationship between these disclosures and the SIM financial statements is not given.

Note 19   Financial Risk Management

• Note 19b Credit Risk
  • 71% of the $7.62 m of financial assets are held in unspecified ‘Non-Bank Financial Institutions’ without any security.

• Note 19c Exchange Rate Risk
  • The fact that the USD account has been overdrawn for the last two years at balance date does not support the statement that the normal balance of the account is USD250K.

• Note 19d Interest Rate Risk
  • The need to hold funds in ‘bank deposits and other investments’ in order to pay for expenses prior to the receipt of funds does not explain the holding of $7.62 m.

Note 21   Retirement Commitments

• Where are these liabilities in the balance sheet?

Note 22 Charitable Fundraising Donations

• Note 22b How appeal monies are applied
  • What document contains the ‘fund charter limits’ for administration and promotion expenses?

Membership of accountability organisations claimed

• None claimed.
• SIM is, however, a member of Missions Interlink.

(End of review)

[i] Australian Charities and Not-for-profits Commission, Australia’s national regulator of charities.

[ii] This is how the ACNC explains ‘operating locations’ in their application guide: ‘You need to give details about where in Australia your organisation conducts (or plans to conduct) its activities.’

[iii] Because of the possibility of two (or more) directors having the same name on the register of responsible persons, it is not possible to be definitive about the number of directorships held.