NSW Wildlife Information Rescue and Education Service Incorporated (WIRES) is Australia’s largest wildlife rescue organisation.
WIRES established an Emergency Appeal (the Appeal) in November 2019 to help support wildlife in response to drought, bushfires and extreme weather events. As a result of significant international exposure and an influx of donations, WIRES expanded its activities to support wildlife at a national level.
By March 2020, the Appeal had received over $82 million and WIRES had received significant national and global attention. By 31 July 2020, WIRES had received $91 million in donations to the Appeal.
Based on the evidence available, we are satisfied that WIRES:
- is spending bushfire donations on bushfire-response activities
- is taking a strategic and reasonable approach to the disbursement of funds
- is taking adequate steps to protect the funds against fraud.
WIRES is developing its policies and procedures in response to changes brought about by the bushfire donations and operations in response to the bushfires. WIRES is aware that it does not have the administrative capacity nor the governance framework to manage its new financial and operational position. WIRES recognised that it was not equipped for the amount of money it received from donations for the bushfires. WIRES is taking positive steps to improve its capacity by engaging an external consultant to assist with its strategic plan and structural review. WIRES has a robust three-step framework in place for financial disbursement. It is looking to add a grants assessment panel to support its move to a framework for national grants.
WIRES is a wildlife rescue organisation with over 3,000 volunteers in 28 WIRES branches in NSW. WIRES’s mission is to actively rehabilitate and preserve Australian wildlife and inspire others to do the same. WIRES achieves this mission by supporting NSW branches involved in the rescue and care of wildlife, running a dedicated rescue office that operates 24 hours a day every day of the year, and providing accredited rescue, care and specialist wildlife training. WIRES is an association incorporated in NSW. It is endorsed by the Australian Taxation Office as a Deductible Gift Recipient (DGR) for its WIRES Public Gift Fund.
WIRES is governed by a Board appointed by the membership. The Board is elected from the WIRES Council, which consists of one elected representative from each WIRES branch and one representative from each of the six species teams. Under the WIRES constitution, all branch members must be members of the association and all members must be attached to a branch.
WIRES Public Gift Fund
The WIRES Public Gift Fund (WPGF) is established under the WIRES constitution to comply with requirements of the Commonwealth’s Register of Environmental Organisations (REO) to receive tax deductible donations. It is established for the specific purpose of supporting the environmental objects of WIRES. WIRES advised that donations for the Appeal went into the WPGF. Donations to the WPGF can only be applied for purposes specified in the objects as set out in WIRES’s constitution.
The WPGF is managed by a management committee appointed by the WIRES Board. The WPGF management committee acts independently of the WIRES Board.
The 2019-20 summer bushfires
Prior to the 2019-20 summer bushfires, WIRES’s principal activity was the provision of wildlife information and rescue services throughout NSW. WIRES is a large charity with total gross revenue of $3,402,991 in 2018-19.
On 11 November 2019, WIRES established an Emergency Appeal to help support wildlife in response to drought, bushfires and extreme weather events. WIRES announced and regularly promoted the Appeal on its website and social media platforms.
On 21 November 2019, WIRES distributed $120,000 to 12 branches it identified as being the worst affected by bushfires and drought. WIRES distributed a further $560,000 to branches on 7 January 2020.
By 21 January 2020, WIRES had:
- distributed over $1 million to its branches for immediate local use and/or emergency requirements
- provided 1 year’s free membership to every current member
- approved a food subsidy for WIRES carers, covering 100% of all food costs for fire, drought and heat affected animals in care for 2020.
On 10 January 2020, WIRES CEO Leanne Taylor released a statement announcing WIRES would allocate funding to support all states and territories assist animals affected by the bushfires. This was a change from WIRES’s previous operations, which were based solely in NSW.
On 22 January 2020, WIRES announced the WIRES Wildlife Relief Fund Grants Program to provide critical emergency support to national rescue organisations, licenced carers and vets assisting wildlife affected by bushfires and drought. Over 240 projects were supported and over $2 million subsequently disbursed.
Between January and March 2020, WIRES received over $82 million in donations from both within Australia and overseas. WIRES received significant third-party promotion, including internationally, which contributed to the significant level of donations.
In addition to donations, WIRES also received a significant increase in volunteers and membership from people who wanted to contribute to the response. Between September 2019 and March 2020:
- 2,112 people enrolled in WIRES’s Rescue and Immediate Care Course compared to 545 for the same period in 2018-19
- 638 new members joined compared to 306 for the same period in 2018-19
- 141 memberships were renewed compared to 67 for the same period in 2018-19.
The bushfires and the subsequent celebrity endorsement increased WIRES’s public exposure, with visitors to its website growing from 321,284 (January to July 2019) to 4.8 million (January to July 2020). WIRES also saw an increase in submissions of its contact form, inbound calls, calls to WIRES Rescue Office, and rescue and wildlife related enquiries.
WIRES advised the Royal Commission into National Natural Disaster Arrangements on 31 July 2020 that the total amount of funding it received to the Emergency Appeal was $91,457,292.
Question one: Is WIRES spending bushfire donations on bushfire-response activities?
The total amount of revenue reported in the WPGF profit and loss statement ending 30 June 2020 was $95,342,295.74. In addition to the donations it received in response to the 2019-20 summer bushfires, WIRES received $3,080,522.99 in grant income from various organisations to deliver bushfire-response projects. Each grant had an agreement stipulating the terms, time frames and reporting and acquittal requirements.
WIRES’s activities are limited by its constitution. It can apply its funds to a reasonably wide range of activities supporting animal welfare, including rescuing and caring for sick, injured or orphaned native wildlife, training members and other licenced wildlife rehabilitators, advocating for and informing the public about the habitat requirements of native wildlife, and undertaking research.
In addition to its rescue, rehabilitation and recovery objects, WIRES may undertake and encourage research in line with its objects and may enter into arrangements with any government, government authority or private body aligned with its objects.
WIRES promoted a broad intent for its Appeal, maintaining donated funds would be used towards drought, bushfires and extreme weather. The breadth of the Appeal’s intent, in accordance with WIRES’s objects, provides WIRES flexibility when allocating and disbursing funds. To date, the grant programs aligned with supporting bushfire response and recovery. Some of the research grants WIRES intends to support will target broader animal welfare issues while concurrently supporting the bushfire response.
In January 2020, WIRES announced the Wildlife Emergency Relief Fund, a national grants program to support licenced rescue groups, wildlife carers and vets affected by bushfires and drought.
The grants are broken into three tiers:
- Tier 1 – licenced individual wildlife carer, not part of a group: maximum $5,000
- Tier 2 – licenced wildlife rescue organisations and groups representing wildlife carers: maximum $20,000
- Veterinary clinics: maximum $10,000 or larger amount for approved projects.
WIRES staff checked that applicants were in areas affected by bushfire, drought or heat. WIRES allocated and distributed $2 million to licenced rescue groups and individual carers. It allocated $1 million for eligible vets and $730,000 has been disbursed. These funds supported immediate relief action, primarily the treatment of animals affected by the bushfires.
On 4 March 2020, WIRES released its ‘Emergency Wildlife and Recovery Plans’. WIRES intends to allocate funding to three key focus areas:
- Immediate response and rescue
- Rehabilitation and relief over five years
- Recovery and risk-reduction over five years.
WIRES’s initial focus has been delivering the $7 million allocated for immediate search, response and rescue phase. The long-term plans include funding projects and research that address the effects of the changed landscape and supporting a national framework to engage volunteers in the rescue and rehabilitation of wildlife affected by bushfire, drought and extreme weather.
WIRES is aware that it will have to allocate funds for operating costs related to the Appeal. At this time an exact figure is not available.
The following table shows the estimated allocation from Emergency Wildlife and Recovery Plans, as well as the allocations and disbursements that had taken place by September 2020. Note that some figures from September 2020 are higher because WIRES continued to receive donations after releasing its plans.
Table: WIRES Emergency Wildlife and Recovery Plans
|Program||March plan||Allocation at September 2020||Disbursement at September 2020|
Rescue and response – 1-year response
|$7 million||$7 million||$7 million|
Rehabilitation and Relief – 5-year response
|$45+ million||$63 million||$425,000|
Recovery and Risk Reduction – 5-year response
|$25+ million||$17 million||$2.1 million|
WIRES has partnered with leading national environmental groups, rescue groups and universities to identify and fund projects designed to deliver the best long-term effects. Its partners need to hold relevant registrations and licences to be funded by WIRES.
Emergency animal rescue and care
WIRES partners with other organisations to assist emergency animal rescue and care needs. For example, WIRES partnered with Animal Rescue Cooperative (ARC) and Currumbin Wildlife Hospital. Identifying ARC’s network of volunteers and transport, WIRES partnered with ARC to provide on-the-ground support to deliver feed and medical supplies to wildlife carers affected by drought, bushfires and extreme weather nationally. This included a financial partnership in wildlife food donations. WIRES continues to work with ARC.
WIRES is funding the construction of a hospital extension at Currumbin Wildlife Hospital to help build capacity for the increasing numbers of sick, injured or orphaned wildlife. WIRES is also funding a dedicated emergency rescue responder and emergency vehicle based at Currumbin.
Threatened species programs
WIRES has partnered with the following organisations with the aim to restore native wildlife populations:
- Australian Wildlife Conservancy: WIRES is funding bushfire-recovery projects with a focus on saving the Kangaroo Island Dunnart and Northern Bettong from extinction.
- Koala Health Hub (University of Sydney): WIRES provided a three-year grant to support koala care, management and research.
Wildlife recovery and habitat protection
WIRES has the following partnerships with organisations to establish local programs to support and protect existing wildlife populations:
- Landcare Australia to fund a national grants program for environmental groups. The Wildlife Relief and Recovery Grants were developed to support the recovery of wildlife habitats affected by bushfire and drought
- World Wide Fund For Nature Australia (WWF) and other organisations to distribute water stations to fire and drought affected areas
- Aussie Ark to support long term recovery of native threatened specifically, species recovery and habitat programs. The funding is for three years and is to assist three bushfire recovery habitat projects and 15 threatened species projects.
WIRES advised us of two upcoming projects:
- WIRES has been working on improving its rescue and care capacity both internally and nationally. It has created an online Introduction to Wildlife Rescue Course that will be made available to national groups through training grants
- WIRES will provide $10 million in emergency wildlife support to prepare for the 2020 bushfire season. The support will include conservation projects, national emergency wildlife rescue and a research program developed with the Royal Zoological Society.
Based on the evidence available, WIRES has spent the donations received in the Emergency Appeal on bushfire-related activities.
Question two: Is WIRES taking a strategic and reasonable approach to the disbursement of funds?
WIRES has engaged an external consultant to develop a long-term growth strategy, during which the consultant will also review WIRES’s structure and governance. WIRES advised the ACNC that development of its strategic plan is in its final stages. WIRES has also employed staff to increase capacity in critical areas, including IT and grant management.
The Wildlife Emergency Relief Fund is the first time WIRES has operated nationally and distributed cash grants. WIRES has always had the desire to undertake such activities but previously did not have funds available to do so. WIRES did not seek external advice, rather it relied on the advice of the lawyer on its Board. The Board approved the decision for WIRES to go national.
WIRES intends to continue operating nationally. It is developing a National Grants Program framework and although it is currently in draft, it demonstrates strategic thinking about the future use of funds. The grants program is intended to assist with wildlife rescue emergency preparedness and the ongoing recovery of wild populations and habitat.
There is no evidence to show that donors expected their donations to solely be used in NSW. WIRES has operated on the assumption that it is likely that the people who donated to WIRES did so expecting the funds to be used to assist wildlife in any state or territory affected by bushfires.
WIRES stated that local community contacts provided the best source of information for animals affected by bushfires. WIRES partnered with ARC to use its network to reach national wildlife carers and WIRES branches.
By going national, there is a risk that WIRES provided support to carers and vets in states not affected by bushfires. WIRES released a grant overview that provides in detail the support provided during the 2019-20 summer bushfires. The overview shows that Victoria received the majority of support with WIRES supporting only two projects in the Northern Territory and one in the Australian Capital Territory.
WIRES is partnering with well-established national organisations that are known to WIRES. It believes that the best outcomes for animals can be delivered through increased collaboration across rescue, conservation and environmental groups.
For the projects that relate to the Emergency Appeal, in addition to WIRES’s general criteria for reviewing major partnerships, it considers the relevance of any planned activities to:
- provide both short and long-term support for wildlife to improve recovery outcomes for all native species in the wake of the drought, extreme weather and bushfires of summer 2019-20
- provide support to wild populations to assist with species and habitat recovery
- increase ongoing emergency rescue and care capacity and be able to respond better to assist more wildlife in the face of future emergencies
- assist with the conservation of any of the 119 species identified by the Government Expert Panel as most in need of urgent intervention after the bushfires.
WIRES, like many other charities during the bushfires, noted the challenges of accessing timely and accurate data and information. For example, there is no central register available for licenced or authorised wildlife carers and each state and territory operates under different licencing systems.
A challenge for WIRES in the recovery period will be obtaining good information to understand the work that is needed. At present, there is a lack of baseline data on animals that have been affected by the bushfires. WIRES advised that it consults with various stakeholders to determine how best to respond to have the greatest effect for wildlife recovery.
Until January 2020, WIRES operated solely in NSW. For an organisation that has only recently commenced national support, it is considered reasonable that WIRES partner with established national organisations. These organisations already have the networks, resources and frameworks in place to effectively deliver agreed projects.
In most cases, WIRES provides funding for projects while its partners administer and deliver the projects. However, for the Water for Wildlife project with WWF, WIRES is accepting and assessing applications.
WIRES is drafting an investment policy to deal with surplus funds. The investment policy will inform short-term and long-term financial decisions and will be informed by WIRES’s strategic plan when finalised. As funds held by WIRES, including any profit made through its investment policy, are ‘charitable funds’, WIRES must use them in line with its charitable purposes. There is no evidence to suggest WIRES will not do this, but it must be careful in designing its investment strategy so that any profits are retained by WIRES for use on charitable purposes.
Donor expectations and transparency
WIRES received criticism from sections of the community for its intention to use donations on activities such as research and staff training rather than solely on the direct care of animals. WIRES also received criticism from wildlife carers (both national and in WIRES branches) for being too slow to distribute cash support.
WIRES undertakes vetting processes to ensure grants are distributed to eligible applicants for an intended purpose. The checks are manual and take time, which explains the delays in delivery and disbursement of funds.
In response to the criticism, WIRES published Bushfire Funding FAQs on its website on 26 February 2020. Largely, WIRES has been transparent with donors about its use of funds from bushfire donations by providing regular updates about its partnerships and projects on its website and social media platforms.
Rapid upscaling and staffing
As donations increased, WIRES initially focused on areas requiring key staff. For example, finance staff to handle the influx of transactions, a project and grants coordinator to track all incoming and outgoing grants, and a chief technical officer to assist with IT controls.
Since the bushfires, WIRES has rapidly increased the number of staff overseeing its grant administration and call centre. WIRES advised its next focus will be on managing its increased membership, training staff in grant administration and supporting animal carers.
These actions are likely to increase WIRES’s administration costs but they will be necessary to deliver its programs.
Based on the evidence available, WIRES is taking a strategic and reasonable approach to the disbursement of funds. Its initial response was to deliver aid where possible to assist affected animals. This required only a fraction of the total received by WIRES, and it is in the process of developing animal welfare programs for implementation over five years. Each of these activities appear to be aligned with WIRES’s purposes.
While it may appear that WIRES has been slow to distribute funds, it actively worked to implement response programs – it spent approximately twice its total 2018-19 revenue in the first few months of 2020, after which time there was reduced need for further response spending.
WIRES has grown significantly both in finances and operations. It is in the process of completing a strategic plan with the assistance of an external consultant. WIRES will no longer operate solely in NSW and has expanded nationally. Due to WIRES’s structure and limited administrative capacity, its approach of partnering with well-established project partners to deliver programs and the rollout of a national grants program is considered reasonable. Managing this level of growth is challenging, but necessary for WIRES.
It now has significantly more funds to manage and a greater ability to deliver effective programs. While the ACNC would prefer to see additional governance in place, the circumstances explain why the controls were not there when the donations were received, and we are encouraged that WIRES has actively identified gaps and is improving its practices.
Question three: Is WIRES taking adequate steps to protect the funds against fraud?
WIRES does not have a fraud protection plan nor a documented fraud framework, but it advised that it is developing a policy. WIRES has implemented vetting and acquittal processes for its grant and partnership programs. Based on the available evidence, the charity does undertake adequate due diligence to protect funds against fraud.
WIRES has vetting and acquittal processes for its grant program. It conducts eligibility checks on all applications prior to approving funds. Individual and group recipients of grants from WIRES must hold an appropriate permit from the state in which they reside and must provide a referee. WIRES contacts state licencing authorities to confirm permits and to enquire about welfare concerns. For Vet Grants, clinics must have treated wildlife affected by emergencies. Wildlife Carer grant recipients were asked to recommend local vets and WIRES cross-checked the list with applicants. As part of the assessment, WIRES took several steps to establish the validity of the applications, which included using mapping from the Rural Fire Service and information from the Bureau of Meteorology to confirm an applicant was in an area affected by bushfire, drought or heat events. WIRES assessed each item individually. WIRES gave all grant recipients its terms and conditions. Internally, all applications were assessed by a minimum of two staff and the CEO to provide oversight.
WIRES received 289 grant applications, of which 66 were unsuccessful.
WIRES requires grant recipients to acquit the funds provided to them. Successful applicants were given 12 weeks to spend the funding and complete projects and, on completion, had to provide an acquittal report. WIRES conducts random audits of grants, requesting invoices and receipts to check against reported spending and approved budget. Grant recipients were advised by email to retain all receipts for WIRES as part of its auditing program.
The draft National Grant Program framework includes a risk analysis framework that considers the risk of fraud, partnership and grantee failures. This should provide guidance to staff on assessing applications. WIRES also noted that it intends to appoint a grant assessment panel rather than continue to rely on staff and its CEO. The engagement of a panel, particularly with external expertise, will support decision-making and will be most beneficial for large grants that WIRES approves.
Given the circumstances WIRES faced, its approval and acquittal processes provide practical assurance that it is giving funds to appropriate recipients. WIRES’s governance and protection against fraud will be strengthened when it develops its fraud prevention strategy. Having a formal strategy is appropriate given the amount of funds WIRES now controls.
WIRES take steps to ensure proposals for partnerships meet its criteria and align with its objects and the intent of the Appeal. Proposals are reviewed and approved internally by WIRES staff, the WIRES Board and the WPGF management committee prior to disbursement. WIRES has written agreements with partners, including agreed terms, time frames and reporting and acquittal requirements.
The WPGF management committee has oversight and authorisation for the disbursement of all funds in the WPGF. As required under REO guidelines, the WPGF management committee acts independently of the WIRES Board.
WIRES has a comprehensive Branch Treasurers Manual to assist elected treasurers of each branch in their day-to-day operations. Appeal funds dispersal is managed at the branch level. Members make a request to the branch executive who submit a fund requisition form to WIRES’s accounts area.
Internal IT controls
As a result of increased international exposure, WIRES identified a spike in online fraud attempts. WIRES identified its security levels were no longer sufficient to protect it from new and additional security threats. WIRES took the following steps to improve its internal IT controls:
- Upgraded its website servers to include a new payment gateway with improved fraud guard monitoring and prevention to maintain Payment Card Industry Data Security Standard compliance
- Engaged a cyber support service to provide monitoring services and security protocol recommendations
- Engaged Microsoft to assist with upgrades to Office 365
- Contracted a chief technical officer.
The significant increase in transactions and increased risk of card testing resulted in WIRES having to process refunds. WIRES follows a written refund process when processing refunds.
Based on the evidence available, WIRES has taken adequate steps to protect its funds against fraud. WIRES responded appropriately to identified security threats that arose from increased international exposure. It has implemented preventative measures to ensure funds are disbursed to eligible recipients for intended purposes. It has acquittal processes in place for grants and partnerships.