Archived: The Archbishop Of Sydney’s Overseas Ministry Fund, charity review

This is a charity review, a review for those with an interest in the Australian charity The Archbishop Of Sydneys (sic) Overseas Ministry Fund (ASOMF).

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

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 25 April 2016, and invited them to comment. Their responses that remain relevant are included throughout the review.

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. This also applies to the information in the Financial Report.)
• 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 name
• The website belonging to Anglican Aid (see Legal Name, below).
• Not on social media, or LinkedIn.
• State government fundraising licence registers.
• No reviews yet on Glass Door. (Nor for Anglican Aid.)

REGISTRATION DETAILS

Entity Subtype

• A subtype consistent with sharing the Gospel.
• According to the trust deed (see Charity’s Document (sic), below) the purpose is ‘the development of ministry by providing assistance to persons and organisations’. These persons and organisations may be sharing the Gospel.

CHARITY DETAILS

Legal Name

• ASOMF is an unincorporated body, a trust fund, that was established by (redacted on the deed, but presumably the Archbishop of Sydney at the time) in 2000.
• Not to be confused with the Archbishop’s other four charities:
  • The Archbishop Of (sic) Sydney’s Anglican Aid
  • The Archbishop Of (sic) Sydney’s Overseas Relief And (sic) Aid Fund
  • Archbishop Of (sic) Sydney’s Discretionary Trust
  • Archbishop of Sydney’s New Churches for New Communities Public Ancillary Fund
• The first, trading under the unregistered name Anglican Aid, is ASOMF’s trustee.
• Anglican Aid is the trustee of the second charity.
  • Given that Anglican Aid runs its own operations and its trusteeships from the one office, reports on them in its Annual Report as its ‘three funds’, and all three charities have the same directors, one wonders why
    • they don’t present consolidated financial statements, especially as the canon law governing their financial reporting requires a ‘charities group status report’ for Synod using the criterion for consolidation that is in the Australian Accounting Standards, and
    • they don’t take advantage of the ACNC Act’s group reporting provisions, thus simplifying their reporting requirements to the ACNC (both Annual Information Statement and Financial Report).
• The third charity has one responsible person, the Archbishop. He controls the income, the Archbishop-in-Council the capital.
  • Ministry response: ‘This entity is unrelated to ASOMF’
• The last charity has a company trustee, itself a charity, NCNC Funds Limited. It has three directors, but they sit at the will of the single member, the Archbishop.
  • Ministry response: ‘This entity is unrelated to ASOMF’

Charity ABN

• Tax deductibility: No, you can’t claim a tax deduction for a donation to ASOMF .

Charity Street Address

• No postal address separate to that of its trustee (from its website): PO Box Q190, QVB Post Office NSW 1230

ANNUAL REPORTING

• AIS 2015
  • This is ASOMF’s compulsory Annual Information Statement 2015 (AIS 2015).
  • Why has Anglican Aid, the trustee, not taken advantage of the group reporting provisions of the ACNC Act?
    • Ministry response: ‘Will consider at time of next lodgement’
  • The AIS was submitted five and a half months after year end, two weeks before the normal deadline.
    • Ministry response: ‘Submitted within initial time allowed – will seek to lodge earlier in 2016’
  • It gives basic financial information.
    • This information agrees with the Financial Report.
• Financial Report 2015
  • It is its status as a ‘Basic Religious Charity’ that makes this not required.
  • However, when I requested the Report, it was sent quickly. And it is now lodged.
  • The Report was signed two months after year end.
    • Ministry response: ‘Allowing time to complete accounts, have them audited and presented to Board meeting’
• 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
  • There is no statement of faith in the governing document (see Charity’s Document (sic), below).
  • Nor, I think (no search function), on the trustee’s website.
    • Ministry response: ‘Correct – will be reviewed – As an aside, Board members are required to sign a statement of faith’

Date Established

• The only history on the trustee’s website has the date a year earlier (at the bottom here).
  • Ministry response: ‘To be reviewed to ensure correct’

Who the Charity Benefits

• Vision and Mission
  • None found.
• Activities (What did ASOMF do?)
  • From the Description of charity’s activities and outcomes in the AIS 2015:
    • The charity supported some 281 students in 9 African countries by providing bursaries and scholarships for theological education. The fund receives donations from supporters which are not tax deductible.
      • It appears that this training of people to share the Gospel as part of their future work, rather than directly sharing the Gospel, is the entire mission of ASOMF:
        • Ministry response: ‘Correct’
        • It exists to help ministries in the developing world by providing financial support for Bible training.
• Outcomes (What did ASOMF deliver?)
  • ASOMF did not respond to the invitation in the AIS for a description of its outcomes.
    • Ministry response: ‘Will review this opportunity for 2016’
• Impact (How were people’s lives improved?)
  • Nothing systematic found.
    • Ministry response: ‘Will review this opportunity for 2016’

Financial Year End

• This means that the next AIS is due by 31 December 2016 (or 31 January 2017 if the ACNC is generous again.)
• Before that the financial information on the Register will be up to 18 months out-of-date.
  • You may therefore want to seek more up-to-date information.

WHERE THE CHARITY OPERATES

Operating State(s)

• ASORAF is exempt from the fundraising licence requirements in this state.
• However, it raises funds all over Australia, so probably has to comply with the fundraising legislation elsewhere. No fundraising licences are held.
  • It is possible that it is exempt in Victoria, but what about in the other six states that have a fundraising regime?

Size of Charity

• ASOMF is only $41K under the threshold for ‘Medium’. (It’s expenses were $17K over though.)

CHARITY’S DOCUMENT (SIC)

• Why is the governing document for ‘ASOMF ‘Rules’, whereas the one for the other fund for which Anglican Aid is the trustee is a deed?
  • Ministry response: ‘The other Fund’s governing document (formerly a Trust Deed) was updated for governance and compliance reasons during 2015. ASOMF’s governing document (the Trust Deed) will be reviewed in due course – not as important due to non-tax deductibility of donations, size and non-member of ACFID’
• There is no Annual Report/Review available on the ACNC Register.
  • Ministry response: ‘We have since lodged – not required, but we want to be transparent’
    • Reviewer comment: There’s still nothing on the Register.
• There is an Annual Report on the trustee’s website, but it is for the group, not just ASOMF.

RESPONSIBLE PERSONS

No. of Australian charity directorships in this name

David Dennis                4

Brett Hall                       6

Douglas Marr              10

John Menear                 3

Emma Penzo                 8

Peter Rogers                 9

Robert Stewart             9

Peter Tasker                 5

Keith Walker                7

• A listing that matches the one on the trustee’s website.
• You would be right to question whether those directors with a large number of directorships – and remember, this is only the number for charities, not all organisations – have enough time to satisfactorily discharge their responsibility under the law for each one.
• No reason was found for the ‘Positions’ to vary between ‘Board Member’, ‘Director’, and ‘Other’.
  • Ministry response: ‘Historical only – there is no difference in substance’

(End of review of the ACNC Register information)

Latest financial report – detail

• The financial statements are produced to the lower standards of special purpose statements. Is it really the case that all current and prospective stakeholders have the ability to request ASOMF to produce for them financial reports tailored to their individual needs?

What was earned, what was consumed during the year – the Statement of Profit or Loss and Other Comprehensive Income (page 3 of the Financial Report)

• Donations $209K, including Note 3
  • This represents 99% of income.
  • Insufficient detail to compare the revenue with the giving options on the website.
  • No bequests were received.
• Revenue from Ordinary Activities
  • The distinction between ordinary and extraordinary has been long gone from the Accounting Standards.
  • A different description is used in the Statement of Changes in Distributable Funds and Reserves.
• Grants Paid $195K, including Note 5 (and Notes 4 and 6)
  • Note 4 Donations Received and Grants Paid $195K
    • This represents 94% of Donations. See Note 4 for how this was possible.
    • The heading doesn’t match the content.
      • Ministry response: ‘Only Designated donations (Designated Purpose receipts) are shown in Note 5’
    • Is there a way of classifying the information in this long list to make the information more useful? By size? By country?
      • Ministry response: ‘Will consider format in 2016 accounts’
• Fund Management Services and other Operating Expenses $72K, including Note 7
  • These represent 27% of expenses.
  • For those expenses that are not disbursements by the trustee, how is it that the figures are so precise?
    • Ministry response: ‘Most costs are apportioned by Trustee on a % basis as approved by the Board at the beginning of the financial year based on projected income – ASOMF income was short of budget, however costs were charged on basis formerly approved. Other costs (audit, Bank charges) are actuals for ASOMF’
  • How does the trustee decide how much to charge?
    • Ministry response: ‘Budget approved by Board on basis on projected income with costs distributed amongst the three funds at the level then approved – this will change in 2016, where percentage will be based more on actual income, rather than budgeted’
  • Personnel Costs $42K
    • Is this the same as ‘employee benefits’ in the Accounting Standards?
      • Ministry response: ‘Covers wages, salaries, allowances, superannuation etc’
    • This represents 16% of expenses.
    • Assuming that part-timers work 50% of full-time hours, and based on the number of employees disclosed elsewhere in the AIS (four part-timers), this represents $21K per employee.
  • Fundraising Costs –$14K
    • This represents 5% of expenses.
  • Missing disclosures:
    • Administration. Note 1(e) equates the $72K of this item with ‘Administration Expenses’. But ‘administration’ doesn’t normally include, for instance, fundraising expense.
      • Ministry response: ‘Noted for 2016’
  • There are no ‘Fund management service fees’ in the list, as implied in the note.
    • Ministry response: ‘Noted for 2016 – traditionally, the “Fund Management Fee” has been split into actual expenses by group with each major cost shown separately – we will not do this in 2016’

Where the cash came from and went to – the Statement of Cash Flows (page 6 of the Financial Report)

• Donations $209K: given the recognition policy, how is it that the cash received is identical, both years, to the revenue earned?
  • Ministry response: ‘Quite right – co-incidence only’
• If accrual accounting is used,
  • why is interest received identical to interest revenue?
    • Ministry response: ‘Because of small sum we show only actual interest received and not any accrued’
    • is it correct that grant payments totalling $195K to multiple recipients were identical to the same grants as expenses?
• Why is the repayment of the loan an operating activity?
  • Ministry response: ‘This represented a payment made by ASOMF in error just prior to end of financial year – was reimbursed by ASORAF in July 2015’

Essential information to go with the figures – the Notes to the Financial Statements – page 7 of the financial report

• Contents
  • As the majority of the Notes are keyed to the statements, is there a need for this page?
• 1 Summary of Significant Accounting Policies Adopted in the Preparation of the Financial Report
  • (a) Reporting Entity
    • Missing information:
      • ‘as an individual entity’
      • The date the accounts were authorised for issue.
    • The directors do not say why they think that ASOMF is not a reporting entity.
    • Do the directors realise that they are effectively saying that all those people who have donated the $209K, and all those people who might donate in the future, are able to require ASOMF to produce a financial report to suit their particular information needs?
    • It is the requirements of the ACNC Act that determine the reporting.
    • Critical accounting estimates:
      • Do they mean ‘IFRS’? If so, don’t their financial statements follow the Australian Standards, not the International ones?
      • It is common for critical estimates to be involved in employee benefits. This is not the case for ASOMF?
        • Ministry response: ‘They don’t have any employees as such’
  • (b) Statement of Compliance: ‘classification aspects’?
  • (c) Cash and Cash Equivalents: up to what length for the term deposits?
  • (d) Revenue Recognition: what about interest?
    • Ministry response: ‘Correct, although any interest accrual would be modest’
  • (e) Administration Expenses:
    • There are no ‘Fund Management Services’ separately shown.
      • Ministry response: ‘See above – we will change in 2016’
    • Direct expenses would not need apportionment.
    • Does the basis for apportionment vary from item to item?
      • Ministry response: ‘Apportioned on basis of projected income – we will change in 2016 to a proportion based on actual income’
  • (g) Goods and Services Tax (GST): cash flows and commitments and contingencies are missing.
  • Missing policy Notes:
    • Current and non-current classification
      • Ministry response: ‘No non-current assets or liabilities’
    • Property, plant and equipment. (It is unusual not to have any.)
      • Ministry response: ‘There is none’
    • Employee benefits
      • Ministry response: ‘No employees’
    • Fair value measurement
  • Ministry response: ‘We will further consider format and contents of notes generally in the 2016 accounts’
• Adoption of New and Revised Accounting Standards
  • How has the impact been assessed as immaterial when the evaluation hasn’t been completed?
    • Ministry response: ‘Wording could be improved’
  • Is this meant to be Note 2?
    • Ministry response: ‘Good point’
• 11. Funds Available for Distribution
  • Grants Paid doesn’t match Notes 4 and 5
    • Ministry response: ‘Total correct, however, all but $500 should be designated purpose’
• 13 Commitments for Expenditure
  • See the comment on Note 4
    • Ministry response: ‘Will review in 2016 year accounts’
• 14 Related Parties
  • Don’t the rules give control of the fund to the Management Committee, whose membership is drawn from Anglican Aid, not the Archbishop?
    • Ministry response: ‘Comment acknowledges ultimate power of the Archbishop’
  • If the Archbishop is in control, then aren’t all the other entities that he controls also related parties?
    • Ministry response: ‘Only because Archbishop at top – there is otherwise no interconnection between the three Anglican Aid Funds and other Diocesan Organisations’
  • Doesn’t Anglican Aid provide ‘administration and staffing’ because it is the trustee, not in addition to its role as trustee?
  • Isn’t some of what Anglican Aid charges an allocation of a larger figure, not just the reimbursement of expenses?
    • Ministry response: ‘Yes – see above – expenses apportioned on basis of projected income of the three funds’
  • The dollars don’t match those in Note 7.
    • Ministry response: ‘Note 14 was the Fund Management Fee component of note 7, other costs included direct Bank fees, audit fees and certain fundraising cost attributable to ASOMF- we will look to clarify in 2016 accounts’
• Missing Notes
  • Remuneration of auditors
    • Ministry response: ‘Only included in note 7’
  • Contingent liabilities (it being usual to say if there aren’t any)
    • Ministry response: ‘Noted – there aren’t’

Where the directors put their name to the report – the Members’ Declaration (page 15 of the Financial Report).

• This declaration doesn’t comply with the ACNC’s requirements.
• The declaration below this one is not required by the ACNC.
• Ministry response: ‘Noted’

Membership of accountability organisations claimed

• Anglican Aid has ‘ACFID Member’ and the Missions Interlink (MI) ‘Accredited Member’ logo in its website footer. The MI membership is in the name Anglican Aid Overseas Ministry Fund, which is ASOMF. Confirmed.
  • Ministry response: ‘.   ‘…we will review wording 2016

(End of review)