The Aid, Development and Evangelism Policy can be downloaded here:
Introduction
This policy informs the assessment of the suitability of overseas activities to receive WorldShare funding. This policy aligns WorldShare’s identification of overseas activities in our international programming with:
● the Australian Government’s Overseas Aid Gift Deduction Scheme (OAGDS);
● the Public Benevolent Institution (Social welfare) criteria;
● the charitable institution (Advancing religion) criteria.
The purpose of this policy is to guide WorldShare to make a clear separation between different types of activities, including development and humanitarian and benevolent relief, and non-development objectives and activities (such as evangelism).
Scope
This policy applies to all overseas WorldShare-funded activities. The policy is applicable to all WorldShare employees and volunteers. The policy also extends to WorldShare ministry partners overseas.
Policy Statement
WorldShare is a Christian organisation. As set out in our Statement of Belief, we acknowledge the commission of Christ to proclaim the Good News to all people and the command of Christ to love our neighbours, proclaim liberty from oppression and spread Christ’s justice in an unjust world.
We acknowledge our legal obligations in relation to our charitable registration and endorsements. We will therefore ensure that our funding overseas is consistent with the purposes and requirements set out by the Department of Foreign Affairs and Trade, the Australian Taxation Officer, and the Australian Charities and Not for Profit Commission (ACNC). WorldShare is committed to ensure that funds and other resources designated for specific purposes, such as the purpose of aid and development, will be used only for those purposes.
WorldShare will ensure that funds and other resources are used only for the purposes outlined in the respective entity’s governing document.
While WorldShare supports integral mission and frequently will support both the evangelistic and aid and development/benevolent relief activities of our ministry partners, WorldShare will demonstrate our ability to separately manage activities under our various entities, such as through separate budgets, expenditure reports and communications with supporters.
WorldShare is committed to ensuring that we accurately represent our activities to the people we work with, our supporters, and the public.
Background: WorldShare Legal Structure
“WorldShare” is the group name for a number of individual entities:
1. WorldShare Australia – Public Benevolent Institution (DGR)
2. Overseas Aid Fund (DGR)
3. WorldShare Christian Mission Trust (Income tax exempt charitable institution – “Advancing religion”)
ACNC has approved group reporting for these entities. Below is a summary of each entity, and a comparison table follows below.
- 1. WorldShare – PBI
WorldShare Pty Ltd, an incorporated Public Company Limited by Guarantee. WorldShare is endorsed with the
ACNC as a Public Benevolent Institution with the purpose of “Advancing social or public welfare”. It has tax
concessions (income tax exemption, GST concessions, and FBT rebate). It is also endorsed as a DGR
(Deductible Gift Recipient). WorldShare maintains authorities to fundraise in each state.
WorldShare must maintain its DGR conditions, which include matters such as ensuring that our Constitution
contain appropriate NFP and dissolution clauses, prevent any kid of distributions or benefits to particular
people that are not in furtherance of a charitable purpose or for the public benefit, a minimum number of
responsible people, annual information statement requirements, and governance standard requirements.
In order to satisfy requirements for a PBI, WorldShare needs to ensure that it is a charitable institution that
has benevolent relief as its main purpose, and that relief is provided to people in need. The charitable
institution aspects of WorldShare are clear.
In addition:
● WorldShare must have benevolent relief as its main/dominant purpose. I.e. it must be for the relief of poverty or distress (sickness, disability, destitution, suffering, misfortune or helplessness).
● The relief must be specifically targeted at people in need and provided to relieve the needs of
those people (and not the broader general community). The Commissioner’s interpretation statement
specifically notes however that “this may be the case for PBIs providing benevolent relief in
developing countries to disadvantaged communities.”2. Cannot be prevention work for the benefit of
the community at large (assuming that the community are not people in need) unless this is incidental
to main purpose. However development assistance (improving the long-term well-being of people in
developing countries through long-term sustainable solutions) is preventative as it stops such needs
occurring – so is considered relief”. The purpose does not have to be to relieve financial hardship or
need caused by poverty, but can relieve other needs (including spiritual comfort needs, as in the case
of counselling or chaplaincy services)
● The poverty or distress that is relieved must be of significant degree “of such seriousness as
will arouse community compassion and thus engender the provision of relief.” The focus ultimately is
on the condition of individuals that the entity seeks to assist.
● Other purposes which are not benevolent must be incidental or ancillary.
● An organisation is not precluded from being registered as a PBI subtype of charity if it provides
benevolent relief to people in countries that have not been declared as ‘developing’ by the Minister for
Foreign Affairs.
● The focus overall should be on an organisation’s purposes, rather than its activities in isolation.
2. OADGS Scheme:
WorldShare operates an Overseas Aid Fund through the Australian Government’s Overseas Aid Gift Deduction
Scheme (OADGS) and gifts made to this fund are also tax-deductible. In order to be part of the OADGS
scheme, WorldShare (when it was called CNEC) applied to AusAid to be accepted by DFAT as an “approved
organisation”. DFAT then advised the Treasurer of its approval, and the ATO then assessed that the fund was
in place and sought approval from the Ministry for Revenue and Assistant Treasurer, who organised the fund to
be declared in the Cth Government Gazette as an approved overseas aid fund to be endorsed as a DGR.
In order to maintain the OADGS scheme, WorldShare must satisfy the following criteria:
WorldShare delivers overseas aid activities, in countries declared as developing countries by the
Minister for Foreign Affairs https://www.dfat.gov.au/aid/who-we-work-with/ngos/Pages/list-ofdeveloping-countries, those activities either being:
a. Development activities (activities which address poverty and its causes and/or address global
social justice issues through improving the long-term well-being of individuals and
communities) which:
i. demonstrate fair distribution (no favouritism or discrimination by race, religion,
culture or political persuasion);
ii. are informed by local people (activities should be identified and designed in close
dialogue and cooperation with local people to ensure that activities are appropriate,
are in direct response to local needs, and build on local capacities – which increases
likelihood of the project carrying on after external activity has stopped); and
iii. deliver sustained or lasting benefits, such as through capacity-building and/or an exit
strategy. The activity itself does not need to be sustained or demonstrate that it is
sustainable, but the benefits which have resulted from the activity should be lasting
and able to be sustained.
- Capacity building recognises that development activities should seek to build the capacity or capability of leaders, communities, organisations, and institutions to create lasting environments which foster the well-being of individuals and communities.
2. An exit strategy recognises the importance of organisations not creating or fostering aid dependency. While it is acknowledged that achieving sustainable change can take a long time, development activities should have clear phaseout or exit strategies that support the sustainable recovery and resilience of the affected population in the medium and long-term.
b. Humanitarian assistance activities which:
i. are in response to a humanitarian crisis (an event or series of events which threatens the lives, health, livelihoods, safety, security or wellbeing of a community);
ii. meet an immediate need (food, shelter, protection, medical attention); and
iii. have an exit strategy (which supports the sustainable recovery and resilience of the affected population)
WorldShare has the capacity to manage and deliver overseas aid activities, which can be
demonstrated through good activity management (which is assessed based on the relevant context,
including the complexities of activities and operating environment):
a. Planning and appraisal – activities are documented in a project plan or similar, and critical
review is carried out to determine whether activities go ahead.
b. Budgeting – activities have a budget, and plans and budgets are reviewed before approval for
support is made.
c. Implementation – dialogue with and support for project partners throughout activity
d. implementation is undertaken and changes to plans are made as needed.
e. Monitor and tracking of progress –implementation is monitored; progress is reported and
reviewed periodically.
f. Financial management – activity expenditure is reported and reviewed periodically.
g. Assessment – the success or otherwise of activities is assessed, lessons are learned and
shared appropriately
Overseas aid activities are delivered in partnership with in-country organisations, based on
principles of cooperation, mutual respect and shared accountability. WorldShare demonstrates how it
cooperates with in-country partners to plan, implement and track progress of the aid activities.
Documented arrangements will exist outlining the objectives of the partnership, the roles of each
party, reporting requirements and financial management arrangements. WorldShare will demonstrate
regular communication between the project partner and itself, and partners will be aware of the
Australian provenance of the funds and support.
WorldShare has appropriate safeguards in place and manages risks associated with child protection
and terrorism:
a. Child protection: WorldShare will have a child protection policy and procedures in place that
promote child protection and child safe practices. Those who have direct contact with children
will undergo Australian Federal Police (AFP) criminal history checks. Where there is direct
contact with children or the project and partners are working with children with disabilities or
children in institutionalised care, additional child safe practices are expected including: that
WorldShare has discussed child protection risks and management procedures with project
partners; and project partners have procedures in place to promote child protection and child
safe practices including child safe recruitment practices, criminal history checks or equivalent,
supervised visits involving children, etc
b. Counter terrorism: WorldShare has a counter terrorism and sanctions policy and procedures in
place that manage the risks associated with terrorism and sanctions. Funds do not support
terrorism or individuals and entities subject to sanctions. The organisation screens developing
country partners, key individuals and entities receiving funds against the Department of
Foreign Affairs and Trade (DFAT) Consolidated List and terrorist organisations listed under
the Criminal Code. The organisation will discuss terrorism risks and management procedures
with project partners and will verify that its project partners undertake terrorism screening of
key downstream partners or suppliers receiving funds against the DFAT Consolidated List and
terrorist organisations listed under the Criminal Code.
They are not ineligible activities:
a. Partisan political activities – supporting a political party, candidate, or organisation affiliated
to a political party
b. Proselytism activities – supporting or promoting a particular religious adherence, including:
i. Activities undertaken with the intention of converting individuals or groups from one
faith and/or denominational affiliation to another;
ii. Using funds to support religious clergy – e.g. priests, ministers, imams, nuns, monks,
rabbis – outside of the context of delivering overseas aid activities;
iii. Using funds to construct or support the running of religious institutions or places of
worship – e.g. temples, churches, mosques.
Further information is available here: https://www.dfat.gov.au/sites/default/files/oagds-guidelines.pdf and here:
https://www.dfat.gov.au/sites/default/files/oagds-eligibility-criteria.pdf
Review- at any future date DFAT may request WorldShare to provide information that demonstrates that
WorldShare is operating in accordance with the OADGS scheme and developing country relief fund
requirements.
Note that the previous criterion and guidelines for the OADGS scheme required that activities not be directed
towards welfare activities (i.e. addressing immediate needs rather than root causes, such as provision of food,
clothing and support for school fees, books and uniforms, and direct child sponsorship). This has been
removed from the current guidelines of the OADGS scheme, so that there is no longer a prohibition of welfare
activities falling within the scheme (however the requirement of lasting or sustained benefits remains).
Similarly, previous guidelines also required that an OADGS organisation show how recipient communities
know that the assistance they are receiving comes from Australian sources – this is no longer a requirement.
Christian Mission Trust
This is a charitable institution with the purpose of advancing religion.
A religion involves a belief in a supernatural being, thing or principle, and acceptance of canons of conduct
which give effect to that belief. Advancing religion involves promotion of those beliefs, principles, observances
and standards of conduct.
Donations to and funds used from the Christian Mission Trust are separately accounted for. It is a controlled
entity by WorldShare and does not need distinct fundraising licenses. The WorldShare Board are the Trustees
of the Christian Mission Trust and approve the Christian Mission Trust financials on an annual basis.
A summary table can be found in the downloadable Aid, Development and Evangelism Policy document.
Policy in Practice
- WorldShare assesses every project to identify and designate through which entity the project will be
supported, and ensure that projects meet the relevant key criteria outlined in this policy. - While the PBI is generally broader than the Overseas Aid Fund, WorldShare will designate at least
three projects each year which as OADGS-funded projects, in order to ensure the ongoing operation of
the OADGS fund. - The distinction between funds and/or resources used for various purposes, particularly those funded
under the OADGS and Christian Mission Trust, will be maintained at all times including in all
fundraising, programs, projects, public communications and annual and other reporting. - WorldShare will ensure that its aid and development/benevolent relief funds are kept separate in its
accounts from funding for evangelism. - WorldShare will ensure that we and our partners can differentiate between development/benevolent
relief and evangelistic activity and communicate this appropriately to stakeholders, donors and the
public. - When providing funding for evangelistic purposes, WorldShare will ensure that funds raised for aid and
development or benevolent relief purposes are not used to exploit people and communities who are
vulnerable and do not place any conditions or obligations on recipients in terms of religious or
political outcomes that would affect their access to services being offered. WorldShare will ensure
partners run aid & development programs in a way that makes clear to participants that participation
in evangelistic programs is not a requirement for benefitting from development programs. - WorldShare will ensure that all its staff, volunteers and ministry partners are cognizant of and agree to
comply with this policy. - All activities funded by or through WorldShare and its partner organisations and relevant staff,
volunteers and contractors will be monitored to ensure they are not in breach of this policy.