So how do you suggest that a church should approach its compliance with the External Conduct Standards?

If you are supporting overseas activities through ACCI Missions or ACCI Relief, then try our Due Diligence Self-Assessment Tool to see how we can reduce your church’s compliance burden. 

If you are not working through ACCI or another ACNC Registered Charity, then we suggest that you consider working through these steps:

  1. Overseas Activity
    • Detailed Activity Assessment (including change goal, methods, motives and good principles)
    • Identify High Risk Activity Flags (including vulnerable people, specialist skills, legal/regulatory requirements and inherently high risk)
    • Activity Risk Mitigation (including sound policies and procedures, good practices standards, codes of conduct, technical skills, training or experience, legal structures and appropriate registrations, oversight bodies and external accountability and reporting)
  2. Implementing Organisation (or Individuals)
    • Partner Alignment, Compatibility and Reputation
    • Legal Structure (including legal status, registrations, governance, accountability, oversight, in-country teams, partners)
    • Organisational and Technical Capacity
    • Financial Controls and Systems
    • Policies and Safeguarding (including children and other vulnerable persons)
  3. Your Church Involvement
    • Your Contribution (including funding, people, equipment and other resources)
    • Your Financial Controls, Systems and Processes
    • Your Policies and Procedures (including HR, child safeguarding, conflicts of interest, counter terrorism, complaints handling and whistleblowers)
  4. Partnership Plan
    • Written Agreement (clearly setting out roles and responsibilities)
    • Document Overseas Activities
    • Budget and Funding/Resource Commitments
    • Risk Management Plan (addressing the overseas activity risks, implementing organisation risks and your involvement risks)
  5. Implementation
    • Progress Reporting (which you require from the implementer)
    • Monitoring and Evaluation (including an annual review of overseas activities and partnership plan)
    • Your Record Keeping (paying special attention to the Standard 2 requirements)

So the end result will hopefully be that your church missions program has participated in a meaningful overseas activity, which has made a positive impact in people’s lives. But it should also mean that you have been able to comply with the External Conduct Standards in the following ways:

Standard 1: Activities and control of resources (including funds). The plan above documents your sound approach to complying with the control of your resources in regards to the overseas activity.

Standard 2: Annual review of overseas activities and record-keeping. The need to keep sufficiently detailed records of your overseas activities has been factored into your implementation.

Standard 3: Anti-fraud and anti-corruption. This has been addressed through your review of the implementing organisation, your own policies and procedures, the progress reporting and annual review.

Standard 4: Protection of vulnerable individuals. The activity risk review should identify up front the degree to which vulnerable individuals may be involved in this activity. Ongoing compliance by the implementor and your own church with the appropriate safeguarding policies will be required. Any other appropriate responses should be specifically documented as part of your risk management plan and reviewed as part of your annual review (at a minimum).