General articles

The Central Council, Ringing Foundation, ITTS, ART and the difficult questions

by Steve Coleman

Our Association has been asked by something called The Ringing Foundation for £1 per head now and £4 per head per year in future. The Central Council is involved in this somewhere, as is the ART. I calculate that £4 per head from the whole country will be £150,000 per year, and that’s major money. So who better than you to explain it all to me?

VERY WORRIED
The Home Counties

A lot of people have been writing to me about this, but so far, I’ve been keeping my head down. The Ringing Foundation and ART supporters believe passionately in what they’re doing – which is splendid – and all the people involved are doing their very best to sustain ringing into the future.

But all the same, I have serious concerns, and there’s surely no harm in people looking at the nuts and bolts of it all. In my capacity as Secretary of The Gloucester & Bristol Association I received the same funding request as all the other Ringing Associations, but since we are a registered charity, I needed to be sure that any donation we made would be in accordance with charity law. Unfortunately, the funding request fell well short of the information needed, so I asked for it.

And here things became a little strange because the Ringing Foundation replied that they would not supply it. Quite likely they found my request irritating, but they said that other Associations had given them money without the information, so if the G&B didn’t want to, that was up to us.

So regrettably, I can’t give you all the details I’d like to, but I can certainly give you some, and I can tell you what’s missing. I can also tell you why I find the absent information concerning.

What it is

So beginning at the beginning, the Ringing Foundation is a charitable company limited by guarantee. It doesn’t have shareholders, it has members. The members are exactly the same people who are the Central Council representatives unless they choose not to be. None of them get any benefit from the company but they all agree to pay up to £10 if it goes bust.

So essentially, the Ringing Foundation is just another CC Committee, albeit with a different legal status. If it’s asking for money, it’s just as if the CC itself is asking for money. If you wouldn’t give money to the CC, you wouldn’t give it to the Ringing Foundation.

How it all started

So why is it that the Ringing Foundation is asking for money, and not the CC? Indeed, why does it exist at all?

Well, that’s due to history. The Ringing Foundation was set up by The Central Council in 2007 following a debate at the annual

meeting. The idea was that a separate company should be set up to raise money from outside of the ringing fraternity. It was felt that it needed to be separate and with no religious connections because some major donors were unable to make donations to religiously-connected bodies. The company would use the money raised to publicise and advance ringing.

What actually happened

So did this happen?

Well, it’s not entirely clear, especially as to begin with the Ringing Foundation seems to have done very little. I asked for copies of their accounts for all years, but they declined to send them even though it would have taken little more than the press of an email key. From other sources I’ve obtained a copy of the 2009 and 2013 accounts but they’re not as fulsome as they might be – see later.

Certainly, though, the donations from the ringing fraternity have been considerable, and the non-ringing donors don’t look particularly religion-adverse. So on the face of it, keeping the Ringing Foundation as a separate charity to the CC hasn’t achieved what it set out to achieve at all. What it has done, though, is made ringers address the question of whether they should be putting more money into the future of ringing.

The Central Council donation

But one odd thing certainly happened on the way. In 2008 or 2009 the CC Officers – who are the Charity Trustees of the CC – made some kind of “promise” to give the Ringing Foundation £10,000. Since I haven’t been given access to the papers I don’t know what kind of promise this was, but since it’s not included as either a liability or a charitable commitment in the 2009 CC accounts, they apparently thought it a very vague promise indeed. If they’d thought it any more than that, the CC accounts would have been incorrect and the Independent Examiners should have spotted it.

The Ringing Foundation’s accounts for 2009, though, said the £10,000 had been “pledged” and that the CC was holding the money on the Ringing Foundation’s behalf. So essentially, the two related charities were both claiming ownership of the same £10,000 at the same time. I’m very unhappy about that, and if it wasn’t that I’m completely confident of the integrity of all concerned, it would raise uncomfortable questions.

And somewhat oddly, the Ringing Foundation’s Independent Examiners couldn’t have picked it up because the accounts tell us that it doesn’t have any. By law it needn’t, but a ringing charity should surely exhibit a punctilio well beyond the legal requirements. Even the smallest Association Branch has its accounts independently examined, so it’s strange that the Ringing Foundation doesn’t.

What happened next

But be that as it may, in 2010 the CC handed over the £10,000. Even to the CC this was a significant sum – over twice the total annual affiliation fees from all the affiliated societies – so naturally their funds went down. And because their funds were going down, in 2013 they increased the affiliation fee by £5 per representative.

And there was something odd about this too, because they also issued a paper saying that none of the affiliation fees was ever used to pay employees. Of course you can find an accounting rationale for any statement, but since the CC had paid £10,000 to the Ringing Foundation, who had paid the bulk of it to the ART, who had paid much of it to an employee, this particular statement seemed less than fulsome. I pointed this out to the writer of the paper but received no response.

Where the funds go

And that brings us to who the Ringing Foundation passes its funds onto.

It has certainly made small donations to a number of ringing projects, but rightly or wrongly, at an early stage it decided to concentrate the bulk of its funds on a teacher training scheme called the ITTS. It set it up and it got it going, and there’s absolutely no doubt that the ITTS courses have been extremely well delivered and extremely well received, and that’s great.

But although I’ve read all the published information most carefully, the technical details of how things developed from there aren’t clear to me, not least because some of the information released publicly has been – inadvertently, I’m sure – contradictory. Suffice it to say, though, there is now another body, the ART, which runs the ITTS and which receives significant funding from the Ringing Foundation. Indeed, over 90% of the Ringing Foundation’s donations have apparently gone to the ART or the ITTS.

The ART

I know many of the ART people personally or by repute, and I’m not in the slightest doubt that they’re all very hardworking and very dedicated, and that they’re all doing what they think is the very best for the future of ringing. But it must be said that they are nonetheless a private and unaccountable organisation who make their own rules and their own decisions, and over whom the CC and ringers generally have no control whatsoever.

Of course, it’s easy to understand why they want to be entirely independent, and if they operated entirely privately and raised their own funds, that would be fine. But it concerns me that they are receiving large “public” funding without even making their accounts publicly available.

It also concerns me that for insurance reasons their system of accrediting trainers could be seriously damaging to the future of ringing. Of course, they don’t agree, and I respect the depth and sincerity of their views; but even if 90% of ringers felt as I do – and even though the ART will apparently receive £16,400 from the Ringing Foundation this year – they can still carry on entirely unaccountably.

So where next?

The phrase that comes to mind here is “No taxation without representation,” and taxation is exactly what we’re talking about because the Ringing Foundation is apparently now contemplating a per capita tax.

According to the minutes of the last Ringing Foundation annual meeting, one director said that “... it was too early to talk about a mandatory levy of £5 per capita.” So the implication was that a mandatory levy of £5 per capita will be talked about – and presumably implemented – later.

But how would it be enforced? Obviously, the only way would be by the CC collecting it through the affiliation fees, and the fact that they’re now talking of the affiliation fee becoming per capita rather than per representative, suggests that the ground is – secretly? – being prepared.

The ART arrangements

And although I’m getting into charity law technicalities here, there’s something else that’s very unusual. Put simply, a charity – the Ringing Foundation – is passing the great bulk of its funds to an unaccountable non-charity – the ART. The Charity Commission’s advice to charities doesn’t even consider this to be a possibility unless the non-charity is a government body of some kind, but it makes clear that any major hook-up of this sort should be subject to rigorous due diligence, risk assessment and documentation. So naturally, I asked the Ringing Foundation to show me the documentation. They declined to do so.

The RF’s 2013 accounts

And that brings us to the Ringing Foundation’s 2013 accounts which have just been passed to me by a CC member.

Put simply, if I were myself a CC Representative I would be seriously concerned, and I certainly couldn’t vote to accept them. Accounts should inform fully, completely and accurately, but in my view these just don’t do that. There are many technical points relating to the adequacy of the information on income and expenditure which I won’t bore you with, but three points are rather important.

First, a note in the Trustees’ Report indicates that a firm commitment has been made to pay £16,400 to the ART in 2014, but there is nothing at all about this in the accounts. So on the face of it the accounts are materially incorrect.

Income

Second, a note to the accounts says:

“Voluntary income is recognised in the period when the company has entitlement to the resources, it is certain the resources will be received and the monetary value can be measured with sufficient reliability.”

But voluntary income is by its very nature voluntary, so the Ringing Foundation never has any entitlement to it until it’s received. And this raises the question of whether the income figure in the accounts is accurate or whether “promised” but uncertain future income is included on the basis of this note.

Reserves and solvency

Third, the Trustees’ Report includes a paragraph headed “Reserves Policy”, but it isn’t a policy at all, it’s simply a statement that the company thinks its reserves are satisfactory.

But clearly the Ringing Foundation should have a reserves policy, and clearly it should state what that policy is – particularly as it’s hard to see why the company thinks it’s solvent. It holds £8,653 but has obligations due in 2014 of at least £16,400 in addition to its expenses. That’s a considerable shortfall which it presumably hopes to make up by way of donations from ringers and Associations.

Default

And that brings me to the last issue that bothered me as a Charity Trustee being asked for money. The Ringing Foundation’s relationship and arrangements with the ART are too opaque.

The ART apparently has a significant financial obligation to pay an employee, and that’s fine. But all sorts of legal responsibilities can go with being an employer, such as the obligation to pay sick pay, maternity pay and redundancy pay. Of course, we all hope the employee remains employed, well and happy, but as they won’t tell me, I just don’t know if the Ringing Foundation has assessed and dealt with the risk. If the worst comes to the worst, is the Ringing Foundation obliged to pay significant sums to the ART without any benefit to ringing resulting? If so, it would be acting outside of its charitable objectives.

The Way Forward

Of course, the Ringing Foundation may well have good answers to some or all of these questions, but if so, why didn’t it provide the information up front? We’re all members of Societies affiliated to the CC, so all this information should have been available to all of us without asking. After all, the CC created the Ringing Foundation; the Ringing Foundation created the ITTS; and the Ringing Foundation are both paying the ART and asking us for the money to do so. What harm is complete transparency?

Steve is happy to answer all other Ringing and Money questions – please  This email address is being protected from spambots. You need JavaScript enabled to view it. him.

 

[Update – since this article was written Rob Parker announced (RW #5377, p.531) that ART has been awarded charity status after satisfying the Charity Commission on issues of its constitution, safeguarding and public benefit purpose.]

See also ‘Very worried of Gloucester is ill informed’ by Bob Hancock.

BB BellBoard
CC
Central Council of Church Bell Ringers