Archived: SIM Australia: mini-charity review

Mini charity review of SIM Australia (SIM), an organisation that seeks donations online, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

• I sent them a draft of this review. Unlike last year, they did not respond^[1].

Is SIM registered?

• As a charity, yes.
• SIM is a public company, a company limited by guarantee.
  • It is permitted to omit ‘Ltd/Limited’ from the end of its name.
• SIM has a licence to fundraise in all seven states that have a licensing regime.
• SIM controls four other organisations:
  • The registered charity SIMaid Trust.
    • It is not mentioned on the website.
  • The registered charity SIMaid Limited.
    • Although the ‘effective date’ of the registration is 4 February 2016, there is no mention of the company in the Financial Report 2016.
    • Its constitution says that it was formed to take over the work of the trust^[2]. Has it taken over yet?
    • It is permitted to omit ‘Ltd/Limited’ from the end of its name.
    • The Financial Report mentions only one ‘SIMAID’:
      • SIM Australia is the trustee for an Overseas Aid and Development fund (SIMAID).
  • The unregistered charity International Christian Fellowship, a charity that SIM merged with in 1989 [Financial Report 2016].
  • The registered charity Africa Evangelical Fellowship, merged with in 1998.
    • No explanation is given why these last two charities remain registered 28 and 19 years after being taken over.
    • Like last year, the Financial Report 2016 says that they are dormant. The Annual Information Statement (AIS) 2016 for Africa Evangelical Fellowship confirms this^[3], but information on the other charity is not available without paying a fee to ASIC.
  • SIM also includes the figures for all four subsidiaries in its Financial Report 2016. A Note in the Financial Report includes the figures for ‘SIMAID’ (the trust/company), but not those of the other two subsidiaries.
  • SIM still hasn’t taken advantage of the ACNC’s group reporting concessions. This means that its subsidiary continues to be in breach of the law by not lodging its accounts.
  • SIM trades under the name SIM. To do this legally, it needs to register it as a business name. (It is presently registered to somebody else.)

What do they do?

• See their website, here.
• More succinctly, in The SIM Effect for 2016:
  • The heart of SIM is mobilising men and women to make disciples and reach those who are living and dying without the Good News. In 2016, 203 SIM Australia missionaries and associates partnered with national believers and churches to share Christ’s love in 30 countries. Thanks to your generosity, $5.4 million was contributed for missionary support and over $1.2 million was contributed for projects expressing Christ’s love to the vulnerable.
    • It appears from the website that the distinction between missionaries and associates is no longer made.

Do they pay their directors?

• Note 19(a) says not.

Do they share the Gospel ^[4]?

• Yes

What impact are they having?

• Nothing systematic under either ‘impact’, ‘results’ or ‘outcomes’ found on the website.
  • This includes in the SIM Effect Report.

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

• There is no line item in the expenses called ‘Administration’.
• In response to their FAQ on the website, ‘How much does SIM spend on administration and fundraising?’, the answer is 5%:

In our last fiscal year, SIM Australia spent 5% of income on administration and fundraising.’

• Only by restricting ‘administration’ to the line item they label ‘Administration, Promotion and Fundraising Expense’, $396K, does ‘administration and fundraising’ equal 5% of expenses. Excluded are
  • ‘Personnel Expenses – Other Staff’ $712K
  • ‘Depreciation – included in Admin Expenses’ 92K
  • ‘Amounts Received by or due to Auditors’ $5K
  • ‘Other Expense’ $172K
  • If these four items are included in ‘administration’, the percentage increases to 17%.
  • And what about the unexplained ‘Ministry Fund Expenses’ $491K?

Can you get a tax deduction?

• No
• SIMaid Trust: No
• SIMaid Limited: Yes, both as itself and for a fund it operates, SIMaid Relief Fund.
  • Presumably this is the projects described under ‘SIMaid’.
• SIM also promotes tax-deductible giving via Steer Incorporated.

Is their online giving secure?

• After selecting the project or missionaries, the page says, ‘Secure checkout’ and has the Rapid SSL logo. This is only base level SSL security^[5].

Where were your (net) donations sent?

• This is not disclosed.

Is their reporting up-to-date?

• Yes (lodged five and a half months after their year-end, two weeks earlier 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 13 months ago.
• SIMaid Trust: Yes (lodged five and a half months after their year-end, two weeks earlier than last year).
• SIMaid Limited: None required yet.

Does their reporting comply with the regulator’s requirements?

• AIS 2016: No.
  • The financial information is for the group, not SIM.
  • Payments to missionaries are shown under neither ‘Employee expenses’ nor ‘Grants and donations made…’.
  • No outcomes are given.
  • Their business name, Fa Fa Better World, has been omitted.
  • SIMaid Trust: No
    • No outcomes are given.
    • ‘Project expenses’, $942K, are not shown as ‘Grants and donations made…’.
  • SIMaid Limited: NA (only registered on 4.02.2016.)
• Financial Report 2016: No.
  • Like last year,
    • The Income Statement does not comply with the Accounting Standards.
    • There are several significant amounts that are unexplained.
    • ‘Missionary Personal Funds’ ($3.38 m received) are included, without explanation, under ‘financing’ in the Statement of Cash Flows.
    • The ‘Closing Balance’ in the Statement of Cash Flows does not match (by a long way) the amount for ‘Cash’ in the Balance Sheet.
    • The Statement of Changes in Accumulated Funds and Reserves diverges markedly from what is required by the Accounting Standards.
    • The accounting for missionaries is not clear.
      • In one FAQ on the website, SIM says that it collects donations on their behalf; in another one it says that they are employees.
    • No depreciation is charged on four of the five properties.
    • Intangibles are incorrectly disclosed.
    • The valuation and disclosure of properties does not comply with the Accounting Standards.
    • Most of the other issues from last year remain^[6].
  • The properties that are to be sold (Note 25), have not been classified correctly.

What financial situation was shown by that Report?

• Ignoring any adjustments that might be required because of the accounting policies disclosed above,
  • The surplus as a percentage of revenue declined markedly, from 6% to almost zero. (This was a return to the 2014 level.)
    • This was due in large part of a 34% increase in the (unexplained) ‘Ministry Fund Expenses’.
  • ‘Cash’ and ‘Financial Assets’ represent 10 months’ revenue.
  • No obvious issues with either short-term or long-term financial structure.
  • 77% of the $7.93 m of financial assets are term deposits held in unspecified ‘Non-Bank Financial Institutions’.

What did the auditor say about the last financial statements?

• The auditor, Lawrence R Green, FCA, Shedden and Green Partners, issued a ‘clean’ opinion.  Before you decide how much comfort to take from this
  • read about audit opinions here and here.
  • re-read the section above.

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

• Not quite – their business name, Fa Fa Better World, is missing.
• SIMaid Trust: No
  • The name is recorded incorrectly.
  • ‘Operates in (Countries)’ is blank.
  • ‘Email’ is blank, but this is not compulsory.
• SIMaid Limited: No
  • ‘Charity Street Address’ is not a street address.
  • ‘Size of charity’ is blank.
  • ‘Email’ and ‘Website’ are blank, but these are not compulsory.

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

• ‘Missionaries’ – 203 of them (AIS 2016)
• ‘Projects’ – six (four of which are tax deductible)
• ‘Where Most Needed’
• ‘Heaven Sent Gifts’ – 14 gifts, 12 of which get you a tax deduction.

Who are the people controlling the organisation?

• The listing on the website is significantly different from that on the ACNC Register (under ‘Responsible Persons’):
  • Amelia Antognelli
  • Jonathan Cheung
  • Robert Cole – not on the website
  • Michael Gordon
  • Alyson Hicks
  • Paul Lukins – not on the website
  • Glenda Norma Mitchell
  • Lawrence Tan
  • Tham Fuan Yee – not on the website
• The website includes Chris Seddon.
• Robert Cole’s ‘Position’ is ‘Secretary’. A secretary is not automatically a member of the board, so this may explain, like last year, why he is not in the website listing.
• Apart from the three SIM charities, the name ‘Robert Cole’ appears on the register for six others. And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  If SIM’s Robert Cole is a director of SIM (see above), and then if after eliminating the charities for which Robert is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.
• There are only 14 members of the company, and as the directors are members, there is very limited, if any, accountability by the membership.

To whom are SIM accountable?

• The answer to their ‘Questions About Donation’, ‘How do I know I can trust SIM with my donation?’, includes this paragraph:
  • SIM Australia is a registered charitable organisation with ACNC as well as members of Missions Interlink. We are independently audited annually by Shedden and Green Chartered Accountants to ensure our finances are in accordance with accounting standards.
  • See the beginning of the review for confirmation of its registration as a charity. See here for the obligations.
  • And here for its Missions Interlink membership.
  • Elsewhere, SIM says that it complies ‘with the standards of Missions Interlink’. See the section Activities in this review for one opinion on the strength of this accountability.
  • As you can see from the Financial Report 2016 section above, the audit by Shedden and Green has not ensured that ‘finances are in accordance with accounting standards’.
• A second paragraph in the above FAQ says that
  • SIM International perform a bi-annual audit to ensure the financial and operational integrity of SIM offices around the world. These internal audits ensure that all programs are meeting the highest standards of financial accountability and integrity. A complete audit report is presented to the National Director and Financial Director of each office.
  • The value of this to a donor is greatly reduced by the fact that the report is not offered to a potential donor.
•  As a company, SIM is also accountable to ASIC.

1. This was their comment last year: ‘Thank you for sending through your updated review. The review was very helpful in identifying several aspects of our reporting which we agree need to be addressed. We are making appropriate changes. I would also want to reassure you that SIM strives to be completely transparent and positive in our response to feedback. As always we encourage existing and potential prayer and financial supporters of SIM projects and missionaries to direct any concerns, complaints or questions to the National Director.’ ↑
2. “The Company, as a subsidiary of SIM Australia, is established to pursue the benevolent purposes of SIM Australia by undertaking overseas aid and development projects previously undertaken by SIM Australia as trustee for SIMAID Fund Trust.” ↑
3. How it has no equity though, is nowhere explained. ↑
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 link is for education, not as a recommendation of a company or product. ↑
6. Contact me if you want a list. ↑