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This is a review, for donors, of the Australian charity The A21 Campaign Limited (A21). 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 need to 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 and invited them to comment. They did not respond. Organisation of this review
- This review is organised according to the headings in the register entry. This is how to use this section of the review:
- For each heading in the register entry, first read the information under that heading.
- 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.
- The ACNC Register entry (including links)
- Internet search on ‘The A21 Campaign’.
- The A21 website, subsidiary websites or Facebook pages (accessible by clicking on the country here), Facebook, and LinkedIn (but not Australian).
- State government fundraising licence registers.
CHARITY DETAILS Legal Name
- There is another charity, Equip and Empower Ministries Limited, which operates from the same office and has the same phone number.
- Tax deductibility: You can claim a tax deduction for a donation to A21.
Charity Street Address
- Postal address: P.O. Box 7820 Baulkham Hills BC NSW 2153
- Make sure Australia is selected in the top left hand corner.
REGISTRATION DETAILS Entity Subtype
- Although I am assured[ii] that A21 is a ‘Christian’ (Christ-centred) organisation, ‘Advancing religion’ is not one of the subtypes, and there’s nothing on the website, in the Financial Report, or in the Constitution to indicate that it is.
- Basic financial information is shown in the AIS 2014. If you think that’s all you might need (or want[iv]) then you should note that, in the Financial Report,
- Employee expenses are considerably less than the $519K shown here, at $166K (Note 3), and
- you should move $10,056 from Other Income to All other revenue.
- The coverage of finances in this review is left until the financial report proper (below).
CHARITY’S DOCUMENTS Financial Report
- This report can be opened either from here or from within AIS 2014 under Annual Reporting (above).
- The Financial Report was completed a little over four months from their year-end, and put on the ACNC Register a month later. This was still within the six month period normally allowed.
- The ACNC allows charities to put their Annual Report or similar on the Register. A21 has not taken advantage of this, nor is there one on their website or an invitation to request one.
ABOUT THE CHARITY Who the Charity Benefits Mission/vision
- In the header on every page of the website: Abolishing Injustice in the 21st Century.
- A very clear description here.
- Unfortunately in the AIS 2014, in response to the request to describe activities and outcomes, it is mostly activities.
- There’s no Annual Report/Review, nor an offer to send one, on the website.
- There are nine stories of individuals helped in the blog category called ‘Survivor Stories’.
Size of Charity
- 2013-14 ‘Revenue’ was $1.6 m, easily exceeding the $1 m threshold for the top size of charity.
Financial Year End
- This means that the next financial report is due by 30 June 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) [v]
- They have a licence to fundraise in NSW, the location of their office, but also in Tasmania. But not in the other five states that have a licensing system.
Operates in (Countries)
- Except for the splitting of the United States into two, this list matches the website.
- Click on the name here to go to the website/Facebook page for the country.
- Feben has been appointed, and Covington and Domingue have left, since the Directors’ Report was signed on 8.05.2015[vi].
- To see all a director’s positions in Australia, search here.
No. of Australian directorships[vii]
Nicholas CAINE[viii] The A21 and Equip and Empower
Kylie DIMAURO The A21 and Equip and Empower
Adrian FEBEN The A21 and Equip and Empower
Jeremy HORN The A21 and Equip and Empower
Loriann LOWERY-BIGGERS 1
(End of review of the ACNC Register information)
Latest financial report – detail Directors’ Report (page 1 of the Financial Report)
- ‘Principal activities’ is missing how these activities helped in achieving the organisation’s objectives.
- You should have also been told the organisation’s
- Short-term objectives
- Long-term objectives
- Strategy for achieving those objectives, and
- How it measured its performance
- If you are interested in the liability of members, it is in Note 13 instead of here.
An independent opinion on the financial statements : the Independent Auditor’s Report (page 5 of the Financial Report)
- The required reference to the ACNC Act is absent.
- The auditor, in accepting the engagement, has assessed the directors’ decision that A21 is not a ‘reporting entity’, and agreed with it. That is, they also think that A21 doesn’t have any users (either existing or prospective) who are dependent on a general purpose report (that is, a report prepared for those who are not in a position to require A21 to produce a report tailored to their needs).
- This is a ‘clean’ opinion. Read here and here to draw the right conclusions from this.
Where the directors put their name to the report: the ‘Directors’ declaration’ (page 7 of the Financial Report)
- For an organisation that has not only ‘Donate’ in its website main menu, but ‘Fundraising’, a selection that invites people to start a fundraising campaign for A21, and received $1.6 m in donations last year you may find it difficult to understand how the directors concluded that all these donors, both current and prospective, have the capacity to command the preparation of financial statements tailored to their needs.
- This decision meant that A21 could produce financial statements that did not need to comply with all the Australian Accounting Standards, and therefore produce statements that the Australian standard setters have deemed not suitable for those people who rely on A21’s financial statements as their major source of financial information.
- An example of the information that you might not get as a consequence is the relationship that A21 has with the other A21 organisations around the world[ix].
- ‘The A21 Pty Limited’ is meant to be ‘The A21 Campaign Limited’, and ‘owners’ should be ‘members’.
- Because A21 is a charity, the reference should be to the ‘the ACNC Act’ rather than ‘the Corporations Act’.
What was earned, what was consumed during the year – the Statement of profit or loss and other comprehensive income (page 8 of the Financial Report) Incoming Resources
- This is not a correct description of what’s included in the calculation of comprehensive income.
Contributions $1.6 m
- We are not told why this revenue almost doubled.
- Or how much was received as a result of donations as opposed to fundraising.
- There is no accounting policy note for this item.
Activities for generating funds $13K (including Note 2)
- We know that A21 sells goods but there is no information – accounting policy or dollars in the Statement of Financial Position – about inventories.
Investment income $10K
- There is no accounting policy disclosed for investments.
- There is no explanation for why A21 is investing donor’s money.
- Why is this figure identical to that for interest income in the Statement of Cash Flows?
Resources Expended Charitable Activities $1.0 m
- You can find a good explanation of these four activities on the website.
- This section uses a classification by function whereas the next section, ‘Supporting Services, classifies expenses by their nature.
- It is therefore not clear whether these four line items include a share of the ‘Fundraising’ and ‘General and administrative costs’ in the next section.
- The AIS 2014 shows that only $440K of this went overseas to achieve A21’s mission.
- This is only 27% of money received from donors.
- We are not told where the money was sent.
Supporting Services $448K
- The cost of the goods that A21 sold is not disclosed.
Fundraising expenses $133K
- There is no explanation of what is included in this item.
General and administrative costs $316K (including Note 3)
- Employee salaries and benefits $166K are the majority of this figure.
- This amount is, without explanation, $353K less than the amount disclosed for Employee expenses in the AIS 2014.
- In June 2015 A21 had six full-time, three part-time and one casual employee, numbers that also don’t fit with the $166K above.
- Intangibles exist yet there is no amortization expense.
- A21 is an international organisation and yet there are no travel and accommodation expenses.
- A21 is not typical in allowing the payment of directors’ fees (see the Constitution under Charity’s Documents. We are not told whether any were paid.
What’s left at the end of the year – the Statement of financial position (page 9 of the Financial Report) Cash and cash equivalents $770K (including Note 4)
- No reason is given for holding such a large amount of savings.
Property, plant & equipment $16K (including Note 6)
- The sale of the company’s property is the reason for the large reduction from 2013.
Intangibles $131K (including Note 7)
- Possible impairment not mentioned.
- Despite the website servicing all A21 organisations, it appears that the Australian company has borne all the costs of developing the website.
Trade & Other Payables $36K (including Note 8)
- There is no provision for long service leave.
How the net wealth has changed – the Statement of changes in accumulated funds (page 10 of the Financial Report)
- If you are trying to understand this statement, note that the $666,992 figure needs to go up one line, and the surplus for the year from the statement two pages back needs to be inserted next to (Deficit)/Surplus for the year’.
Essential information[x] to go with the figures: the Notes to and forming part of the Accounts (page 12 of the Financial Report) 1 Statement of significant accounting policies Basis of Preparation
- It is the ACNC Act that governs the report, not the Corporations Act.
- Given that four of the five A21 directors are also four of the five directors of Equip and Empower, and that the two charities operate from the same office, it is legitimate to question whether one of these charities controls the other.
Accounting policies (a) Revenue
- This note doesn’t match the types of revenue A21 earned.
(k) Critical accounting estimates and judgement
- It is hard to believe that, despite the inherent imprecision of accounting, the directors did not make a single critical estimate or judgment.
(l) New accounting standards and interpretations
- This incorrectly combines two required disclosures:
- New and amended standards adopted, and
- Standards issued but not yet effective and not adopted early. There should be a list under this one.
Membership of accountability organisations claimed
- None claimed.
- It is not possible to check membership of Missions Interlink.
- The US A21 is, however, a member of the ECFA.
(End of review)
[i] Australian Charities and Not-for-profits Commission, Australia’s national regulator of charities. [ii] From a Facebook respondent (after I couldn’t get a response from either of the email addresses on the ACNC Register). I didn’t ask though the extent to which they share the Gospel by word. [iii] The ECFA’s Standard 1 says that Every organization shall subscribe to a written statement of faith clearly affirming a commitment to the evangelical Christian faith, or shall otherwise demonstrate such commitment, and shall operate in accordance with biblical truths and practices. There is no statement of faith on the US website. Note that, even if there were, it does not need to say anything about spreading the Gospel by word. [iv] Those who wrote the rules for the financial statements say that, as a user, you ‘are assumed to have a reasonable knowledge of business and economic activities and accounting and a willingness to study the information with reasonable diligence’ [Framework for the Preparation and Presentation of Financial Statements, www.aasb.gov.au, paragraph 25]. [v] 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.’ [vi] Covington, however, is still a ‘responsible person’ for Equip and Empower Ministries Limited, an Australian charity whose other directors are also directors of A21, and a director of the US organisation. [vii] 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. [viii] Caine and Dimauro are also trustees for the UK organisation, and directors of the US corporation, and Lowery-Biggers a director of the US organisation. [ix] The Directors’ Report has an acknowledgement of the closeness of the relationship between, at least, the Australian and US organisations: The surplus for the financial year was $221,603 compared to a deficit of $142,685 in the previous year, with the increase predominantly due to a significant US donor deciding to donate through their Australian arm to The A21 Campaign in Australia instead of The A21 Campaign in the USA. [x] Accounting Standard AASB 101 provides that ‘The Notes shall: present information about the basis of preparation of the financial statements and the specific accounting policies used in accordance with paragraphs 117-124; disclose the information required by Australian Accounting Standards that is not presented elsewhere in the financial statements; and provide information that is not presented elsewhere in the financial statements, but is relevant to an understanding of any of them [paragraph 112].