Human Aid UK  describes itself as an international humanitarian charity which 'strives to alleviate the suffering of the oppressed' and says it works in collaboration with dedicated partner organisations in remote areas of the world, including Africa, Middle East and South Asia. Its income for the financial year 2016 totalled £679,104.

The Commission’s engagement with the charity began in June 2013, initially over concerns that it had been involved in providing a platform for speakers with what were reported to be controversial and/or extremist views at a fundraising event, although this was subsequently cancelled.

During 2013 and 2014 there were two separate incidents involving the arrest of individuals by the police said to have been conducting unlicensed street collections.

The first arrest concerned an individual who was a volunteer of the charity; part of the police’s enquiries focused on whether a fundraising bucket held by the individual at their home address belonged to the charity. The trustees confirmed to the Commission that the individual was a ‘seasonal’ fundraising volunteer for the charity, recruited to cover a busy period in the lead up to and during Ramadan.

However, the Commission raised concerns as to whether the volunteer held fundraising materials belonging to the charity at their home and, if so, whether they had the charity’s permission to do so.

Subsequently, after the opening of the inquiry, the charity submitted a serious incident report to the Commission advising that an individual had been arrested in connection with fraudulent fundraising and that the individual had claimed to be a volunteer of the charity.

Following this, the trustees informed the inquiry that new procedures around fundraising had been introduced in order to address the regulatory concerns previously raised by the Commission. Each collection bucket belonging to the charity is uniquely numbered and has coded tamperproof seals.

On the day of a collection, volunteers sign out the buckets and any other fundraising materials and are supervised by an experienced fully vetted team leader. Upon returning to the office, volunteers hand in their buckets and any other fundraising materials and sign to confirm their return.

The collection buckets are then counted by a member of the fundraising team along with the finance manager who then both sign to confirm the date the contents of the bucket were counted and how much it contained.

Partner organisations

The Commission’s inquiry concluded that while the charity acted on some of the earlier regulatory advice to address vulnerabilities in its financial controls and management of fundraising, the charity had not exercised sufficient oversight of its work with partners, particularly in areas which are considered to be high risk or where conflict prevails.

The Commission found that the charity’s records and systems regarding its activities in Turkey/Syria and/or on the Syrian border did not sufficiently account for the proper end use of all the funds transferred from the charity to partner organisations.

The inquiry could not reconcile some costs with the records and systems inspected at the time on one project with a partner organisation based in Turkey for an emergency medical service convoy to Syria and found further deficiencies in relation to the charity’s monitoring of the end use of funds relating to a baby milk project with another UK partner.

In December 2013 a payment of £27,000 was made by the charity to the Turkish partner organisation, which the trustees advised was for costs associated with the security, transport and session staff required for an emergency medical service (EMS) convoy.  However, the inquiry found it was not possible to reconcile any of the costs incurred as part of the EMS convoy, as set out in the Turkish partner organisation invoice, to the copy receipts, invoices and bank slips submitted by the charity to the inquiry.

Between March 2011 and July 2014 the charity also transferred approximately £39,150 of charitable funds to another UK charity registered with the Commission. The documentation provided by the charity to the inquiry only supported the cost of projects with the UK partner organisation in the sum of £31,150. The inquiry found no documentation to account for approximately £8,000 of charitable funds, which Human Aid UK said were used for a baby milk project.

The Commission’s inquiry did not find evidence of specific misapplication of charity funds. However, due to the overall lack of adequate documentation to demonstrate the charity’s due diligence checks and monitoring of the end use of funds, it concluded that the trustees had failed to adequately protect the charity and its assets.

The trustees have been directed to carry out a review of the charity’s financial management and controls as well as its due diligence policies and record keeping, which will be monitored by the Commission.

Michelle Russell, director of investigations, monitoring and enforcement at the Charity Commission, said: ‘Many charities doing vital humanitarian work rely on partner organisations to help them carry out activity in the UK and overseas.

'The findings in this report are a reminder to those charities about the need for them to carry out proper due diligence on partners that receive money from or work closely with the charity and proper monitoring and verification of spend of the charity’s funds.

‘A fundamental basic is the need to keep adequate and appropriate receipts and other records of spend and have proper systems and procedures in place to request, analyse, record and hold these on a systematic and regular basis.’

Charity Commission Human Aid UK: Inquiry report is here

Report by Pat Sweet