Memorandum from Christian Aid (DCH 208)
Christian Aid is one of the leading charities
in the country. Established at the end of the Second World War
it has contributed to the reduction of poverty and suffering of
many millions of people across the developing world over the last
60 years. In the last financial year, the charity raised £60
million, the majority from voluntary donations from nearly ½
million supporters.
Christian Aid welcomes the opportunity to comment
on and contribute to the draft Charities Bill. The Bill is welcome
and its purpose, borne out of the review "Private Action,
Public Benefit" is endorsed. Charities have a unique place
in society, hold unprecedented levels of public trust and confidence
and as such this Bill is a welcome step in supporting the sector
to continue to play a vibrant part in civil society.
We have seen the Bates, Wells and Braithwaite
(BWB) submission to the Joint Committee and would wish to support
the points raised in their response. Due to the tight timetable
for consultation Christian Aid was, unfortunately, unable to join
the BWB working party, nor has the trustee body of Christian Aid
been able to respond. The views expressed are therefore, necessarily,
personal.
I would wish to comment specifically on just
two parts of the draft bill.
(i) Chapter 6; section 22 and Chapter 7 section
25—audit threshold
I believe the recommendation to increase the
audit threshold to £500,000 to be inappropriate. Christian
Aid is one of the largest grant making charities in the UK yet
our average grant is just £35,000. The majority of recipient
organisations are charities and Christian Aid is their major funder.
Although the majority of partner organisations are overseas, a
number working on development education and awareness issues are
UK based. In the last year Christian Aid has been amending its
grant-making procedures, as requested by the Charity Commission,
in relation to the giving of grants to recipient charities who
are failing to file accounts on time. The recommendation to increase
the audit threshold seems to be an unnecessary piece of deregulation,
which will undermine accountability not build public trust. Whilst
I understand the arguments for increasing audit thresholds in
the private sector I am not persuaded that such deregulation serves
the charities sector.
(ii) Part 3 section 37—43—Public
collections
I am concerned by the proposed new legislation
particularly as it relates to certificates of fitness. Christian
Aid Week is the largest house-house collection in the country
raising some £15 million for overseas aid through the commitment
of 300,000 volunteers. Whilst the amounts raised are significant,
in proportion to individual collector effort they are not. Increasing
regulation in this area is not therefore proportionate to the
risk of funds being misapplied.
Unlike Christian Aid many other charities are
also recognising that income from house-house collections is diminishing
as societal ways of living change. We do not believe therefore
that increasing regulation in this area will improve accountability
and transparency, but on the contrary will further undermine voluntary
action by the many millions who continue to demonstrate their
commitment to charity through door-door collections.
It is not at all clear what value these certificates,
issued in addition to the existing permit system, will add. This
seems to be compounded by limited grounds upon which a local authority
can refuse to issue such a certificate.
I hope you find these comments helpful and as
said at the outset I look forward to the new Charities Bill with
much enthusiasm.
Martin Birch
June 2004
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