SIM Australia: charity review

This is a review^[1] in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission’^[2] (and a means for a Member to get income tax exemption when it might not otherwise be available^[3]). ‘SIM Australia‘ is one such member.

The website linked from the Missions Interlink membership goes to a website in the name ‘SIM’. Here they seek online donations.

Covid-19

Donors

Given what Missions Interlink does, ‘SIM’ is probably a charity.

The charities’ 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.
5. Find out more about how the charity says it uses donations.

Here’s the results for ‘SIM with #5 supplemented by the essentials of the ACNC’s ‘What should I consider when deciding which charity to support?’^[4]

1.  A search on the ACNC Register of charities gives a charity in that name, Sim Australia (SIM).

• SIM is a member of an ACNC Group. The other members are SIMaid Limited, and Simaid Trust.
• ‘SIM’ is not a registered business name^[5].

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2.  There is nothing to suggest that SIM fundraises door-to-door or in the street.

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3.  The web address begins with a closed padlock symbol, so the website is secure [the ACNC article above]. The logo of RapidSSL (without a link) is on the page before you enter your information.

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4.  The Australian Business Register (linked from SIM’s ACNC Register record), says that the charity is not entitled to receive tax deductible gifts. We have seen above, however, that SIM is a ‘legitimate charity’.

This Register information does not match the information on the checkout page in the giving process. Here it says that ‘*Gifts with asterisk (sic) are tax-deducible’. The reconciliation lies in the fact that the donation process includes one of the other two charities in the Group, SIMaid.

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5.   The use of your donations

As context, here’s what SIM does^[6].

The audited account of how a charity uses donations is the Financial Report on the ACNC Register. Because of the ACNC Group, the Report is for ‘SIM Australia and Controlled Entities’.

• The entities identified by SIM in Note 1 [Notes to and forming part of the accounts] do not match this Group:

• Why is Simaid Trust (see above) not included?
• SIM merged with ‘ICF’ (International Christian Fellowship 31 years ago. Why is it still registered as a company?
• SIM merged with ‘AEF’ (Africa Evangelical Fellowship). Why is it still registered? And as it is also a charity, why is it not included in the ACNC Group (see above)?

Here’s how the donations to SIM were used:

Cash spent

From the Statement of Cash Flows (with last year in the second column):

Not helpful in telling us where the $8.48 million cash went.

Resources consumed (i.e. accrual)

This, from the Statement of Income & Other Comprehensive Income, is how the activities translated into expenses (with last year in the second column)^[7]:

There is no explanation of any of these figures.

• With missionary ‘Salaries & Taxes’ and ‘Housing’ identified separately, what is included in the 17% of expenses that is ‘Missionary Other Expenses’?
• Presumably ‘Project Expenses’ is the money sent overseas. We are not told where^[8], or to whom.
  • Nor does the Annual Report^[9] give this information.
• The whole charity is a ‘ministry’, so what are ‘Ministry Fund Expenses’?
• If depreciation is ‘Included in Admin Expenses’, why is it also included separately?
• How much is consumed by fundraising compared to administration?
• What is the distinction between ‘promotion’ and ‘fundraising’?
• Why is fundraising some portion of the $432K here, but 100% in Note 24:

Directors

Here are the directors who approved the Financial Report 2019:

Amelia Antognelli

Jon Cheung

Michael Gordon

Alyson Hicks

Paul Lukins

Lawrence Tan

Tham Fuan Yew [Directors’ Report]^[10]

The website says that the same people are still on the board, but the ACNC Register says that Wai Sum (Sam) Kong is also a director.

Impact

Nothing systematic found (including in ‘The SIM Effect’, SIM’s annual report).

Charity response

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

We sent SIM a draft of this review on 22 April 2020. They received the draft but chose not to respond.

1. See here for the previous review. ↑
2. https://missionsinterlink.org.au/about/ ↑
3. ↑
4. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community. Is it clear what the charity is trying to achieve and how its activities work towards its objectives? Would you like to spend your money, or time if volunteering, to support these objectives? Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering]. ↑
5. SIM does have a registered name – Fa Fa Better World – but it appears that they are not using it. ↑
6. The ‘Summary of Activities’ on the ACNC Register is brief and out-of-date: ↑
7. Suggestion to SIM: put the expenses in some discernible order. ↑
8. The ‘Summary of Activities’ on the ACNC Register says that SIM is in 30 countries; elsewhere on the Register it is zero (SIM Australia) or 18 (the Group). ↑
9. There is provision on the ACNC Register for a charity to provide its annual report. SIM has not done this. ↑
10. The directors are accountable to the members. A company’s usual disclosure of the number of members is absent [Directors’ Report]. ↑