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The ACNC External Conduct Standards were established in 2019. The standards govern how registered charities must manage their activities and resources outside Australia.

One year on from their arrival, this webinar looked some of the burning issues charities have experienced in complying with the standards over the past 12 months, as well as current challenges relevant to charities operating overseas.

Webinar transcript

Chris Riches

Good afternoon, everyone. Hi and welcome to today's webinar which will focus on the ACNC's External Conduct Standards, one year on.

We hope you're all staying safe and well. My name is Chris Riches. I'm from the ACNC's Education Team. Joining me today is Matt Crichton. Hi, Matt.

Matt Crichton

Hello, everyone.

Chris Riches

Now, as always, super quickly, some housekeeping points before we start. If you've got any troubles with the audio for the webinar, you can try listening through your phone. Call the number listed in the email you will have received upon signup and put in an access code and listen to the webinar that way.

You can also type a question at any time throughout the webinar. We've got our colleagues, Robin, Jess and Matt helping us respond. We'll try to answer all of the questions that come through but if your question isn't answered, please feel free to send us an email and we'll get back to you. You can send those emails to our education address,

Recording of this webinar as well as the slides will be published on the ACNC website in the coming day or so. As always, we'll send out an email with a number of the links that we'll mention during this webinar so you don't have to write everything down and scribble madly.

We've also sent through a handout with those links to those who have registered for today's webinar. Finally, we value your feedback as always. If you've got any suggestions for ways we can improve our webinars, please let us know in the short survey at the end of today's session.

So he says, hitting a button and hoping it works. Let's see what we've got here. There it is. That makes me feel good.

Now, what's on the agenda for today? We're going to firstly run through some context on the standards, what they are, what they cover, that sort of thing.

Matt Crichton

Actually, just before we move on to the rest of these to do list. Just on the handouts, if you didn't get that in the confirmation email, I think you should be able to access it via the control panel and the go to webinar there. So if you don't have them handy and you want them, you should be able to download them there. There should be a little section called Handouts.

Chris Riches

There's two of them.

Matt Crichton

Back to our plan, we will look at some of the common questions and queries that we have received about the External Conduct Standards. We'll provide some answers as well and point you all in the direction of some handy resources and other information that we have about complying with the standards. We will devote a bit of time to looking at the External Conduct Standards in the current challenging climate.

We know there are charities out there facing lots of challenges and we'll provide some guidance and tips on how they can continue to comply with the External Conduct Standards despite the current difficulties.

Of course, there are other issues that have arisen in the years since the External Conduct Standards were introduced. So we'll spend a little bit of time working through those and offer up some support and tips on them as well.

Chris Riches

To round things up, we'll go through some quick tips and key messages and takeaways. We'll, with any luck, get to some questions that we can answer as well and wrap things up.

So the External Conduct Standards, the standards are a set of four standards that set out how registered charities must manage their activities and resources and their people outside Australia.

Matt Crichton

They were introduced this time last year as the title of this webinar suggests and they cover a few things. The first couple here though, they cover a charity's activities and control of resources which includes funds for use overseas. This means the use must be in line with the charity's not-for-profit purpose and character.

The charity must have reasonable controls or policies in place for their use and charities must follow Australian laws. They also cover an annual review of overseas activities and recordkeeping charities need to obtain records and keep them.

The records must allow the charity to prepare a summary of activities and expenditure on a country-country by basis.

Chris Riches

They look also or cover antifraud and anticorruption. The charity has to minimise the risk of fraud and corruption when operating overseas and also manage conflicts of interest which is another important aspect of that standard.

They also endeavour to protect vulnerable people. Charities have to minimise the risk of harm, exploitation or abuse of vulnerable people.

As we can see, the External Conduct Standards have four key aims to ensure confidence in charities' work and their use of resources.

Now, that's money especially, but also other resources as well to promote transparency and to promote accountability and to again, protect vulnerable people. Be they your people, the people working with you or for your charity or the people your charity works with overseas.

Now, the standards apply to all registered charities when they're operating outside Australia or working with a third party that is operating outside Australia. A couple of quick things here, basic religious charities, they are not compelled to comply with the ACNC's Governance Standards but they must comply with the External Conduct Standards and third parties.

Just a quick explanation, generally speaking, third parties are organisations or individuals that either formally or informally work with a charity. Now, we realise that most charities have jumped in. They've done the right thing. They've ensured that they're meeting the standards and by doing so, they've ensured that their governance, their operations and their work are all the best they can be.

Matt Crichton

Now, a couple more little explanations here. Operating outside Australia, as we show on the screen here, means a charity is undertaking activities that are overseas or even funding activities that are overseas.

It doesn't matter how small these activities are. They count as overseas activities and a charity is therefore, in this sense, operating outside Australia even if the funds or the activities are really small. We've got example situations where the standards do and don't apply on a fairly comprehensive factsheet on our website.

We have mentioned the word activities a few times here, particularly overseas activities. Now, there are a number of activities that constitute a charity operating outside Australia and therefore means they have to comply with the External Conduct Standards.

Chris, do you want to go through some of these?

Chris Riches

As you can see here, we've clicked through a couple of slides and there are some examples here of what it means to be operating outside Australia. Sending money or resources overseas is the first one.

That's something obviously quite a few charities do. Now, the standards include specific mentions and provisions when it comes to charities sending money overseas.

External Conduct Standard 1, in particular, provides some clear guidelines and reference points. It's worth referring to that standard to ensure that you know what your charity can do to make sure it meets the standards if it's just sending some money overseas.

Also operating outside Australia encompasses sending staff, volunteers, members or beneficiaries which are those who you aim to help overseas.

Matt Crichton

Another one here, conducting activities overseas. That's pretty obvious. I suppose that's the classic sense that we all understand, having people doing stuff overseas as part of programs or projects that you've got happening in another country.

Buying goods and services from overseas suppliers, that's one that can easily be overlooked but that can be classed as an overseas activity if the purchases are linked to your charity's work in pursuing its charitable purpose.

Working with individuals or organisations located overseas. We've mentioned third parties a couple of minutes ago and generally speaking, working with groups or individuals located overseas, maybe to do some work in overseas communities or distribute funds or goods to those communities.

That may be classed as operating outside of Australia too.

Now, with this whole list we're speaking quite generally. We understand that there may be some obscure situations or some things on the very edges of these sorts of broader categories that may be a little bit harder to categorise or maybe harder to see whether or not the External Conduct Standards apply.

It's worth exploring it further if you feel your charity is doing one of those things. But generally speaking, these are the broader categories that would be encompassed by this phrase, operating outside Australia.

Chris Riches

I guess to that end, as you can see here on the screen, there's three key areas on our website where we would encourage you to go and have a bit of a look. The first link here is to our External Conduct Standards page.

That provides a pretty easy-to-understand rundown of the standards in an overall sense as well as direct links to more detailed information about each of the individual standards. That's a really good starting point.

The second link here on your screens is a link to our guide on when the External Conduct Standards apply. This page is a good one because it provides quite a few practical examples of when they apply or when they may not apply.

There are times where as Matt just mentioned, things can get a little bit involved or a little bit technical. So we've spent some time to go through and to endeavour, to explain things in the plainest possible way on that page and provide some practical examples of when the standards apply or don't apply.

The third link is to our self-evaluation tool. This is a really useful one. It's something we'd recommend any charity that has to comply with the External Conduct Standards at hand. It provides a whole heap of practical steps charities can take to ensure they comply with the standards. It's a great reference point as well.

Again, a copy of that tool has been included as a handout for this webinar. You can access it from that page on the web though. Follow through these links away. We'll be sending out a follow-up email after this webinar. It's going to include those links and others so you don't necessarily have to scribble everything down right now.

Matt Crichton

Some key issues. Now, in the year or so since the introduction of the External Conduct Standards, we've received a fair share of questions from charities about when they apply, what charities have to do to comply, those sorts of things.

We've learnt a fair bit over the past 12 months about what charities are finding difficult and less so, I suppose. We've gathered a few of the more common queries together here so we can offer you a bit more information and guidance that we think may be particularly saline or practical for charities grappling with some of these issues. I'll pass over to you, Chris, to kick these off.

Chris Riches

We mentioned before and we'll mention it again here, the way that charities have jumped in and taken the External Conduct Standards on board has been great. It's been really encouraging, very positive. The way that they've integrated the standards into their planning and work, has been again very positive.

As Matt mentioned, as this webinar is going to detail, there have been some questions though and quite understandably as well. First question here, we're a small charity that wants to send money overseas. Can we still do that? Now, that's one that we've received quite a number of times. Matt?

Matt Crichton

The answer is a pretty clear one. Yes, definitely. Your charity, of course, can still send money overseas. The last thing we want is for the External Conduct Standards to put a blocking in that charitable activity. So of course, the answer is yes but it means that your charity does have to comply with the External Conduct Standards. We'll have a look at what that means in this context.

Chris Riches

In this context that we're talking about, External Conduct Standard 1, emphasises that money for example sent overseas needs to be used lawfully and in line with the charity's charitable purpose.

So it's important here that charities take reasonable steps to ensure that this is the case. Now, as you can see, we've bolded the phrase reasonable steps here. Matt, what are reasonable steps?

Matt Crichton

This is one that can get a little bit tricky for people in charities trying to get their head around the External Conduct Standards. Now, we don't dictate what specific steps charities must take. There's no prescription from the ACNC about this or the level of work that they need to do.

What we say is that charities need to take or the steps that charities need to take must be reasonable given their own size, their own capabilities and the scope of their work overseas.

For some large charities that have a lot of activities outside Australia, they're likely to need more comprehensive and maybe many more policies to ensure that they are complying.

But of course for smaller charities, this is going to be scaled back a little bit or charities that don't have a lot of activity outside Australia. What they would consider reasonable in the context of their own operations would be very different.

So this idea of reasonable steps might include some or all of these things, policies, procedures, approvals, processes for funding or sending money overseas, security checks, background checks of volunteers, staff, and that sort of thing, ongoing monitoring of projects, that sort of thing. But of course back to this phrase, reasonable steps, all of this depends on your charity's work and precisely the scope of its overseas activities.

So although it would be nice to offer a very clear prescription for every charity based on their work, it's not how these work and it is up to a charity to consider their own work carefully and consider what would constitute reasonable steps for them in meeting the External Conduct Standards.

Chris Riches

Some examples in this area perhaps to contemplate is things like checking the recipient of the funding. Is it another charity? Is it based overseas? Is it Australian based doing work overseas? What is your charity funding? Using secure monitored services when transferring funds, formal banking systems, those sorts of things, asking recipients to confirm that they've actually received the funds.

Obviously, continued updates on the work and ensuring that your charity is on the ball and knows what's happening. Charities should ask for regular updates from the organisation carrying out the work.

Record keeping again is another key thing to consider. Keep records of the amount of money that's been sent overseas, to which organisation it's gone to and for what purposes it's been sent overseas.

We'll go to the next question here. We are a church that's a Basic Religious Charity. We don't have to comply with the ECS, do we? Matt, do you want to break the news?

Matt Crichton

The simple answer is yes, you do. Just before we get into some of the details of this, I just want to clarify this idea of a Basic Religious Charity. That's a particular charity category for ACNC registration purposes or reporting purposes.

So it's not that you just describe yourself as both basic and religious and therefore that's it. There's actually a list of criteria that an organisation has to meet to be considered a Basic Religious Charity.

Now, this is a slight detour. There's a page on our website that has the full list of those criteria and exactly what it has to be to be considered a Basic Religious Charity. So if you're unsure, it's worth having a look at that. We'll include a link in the follow-up email.

But just to make it clear that we're not just talking about any charity that considers themselves both religious and basic. It is about meeting a certain set of criteria.

Now, back to the answer to this one which is yes, it is something that a Basic Religious Charity will have to consider. It's important not to write this off as conducting activities overseas in the traditional sense of imagining people from your church working overseas in another country and conducting projects or activities overseas.

As we mentioned at the beginning, it does even include sending money overseas even if the church in Australia doesn't have any people physically doing the work overseas.

Chris Riches

In a sense, we say obviously that Basic Religious Charities do have to comply with the External Conduct Standards.

But I guess from a higher level I suppose, it is important that Basic Religious Charities actually do this. Institutions like these have long been part of a tradition of overseas support work and overseas efforts. We see examples of that. Now, we've seen examples of that all through the years.

If these types of institutions are sending money overseas or have a charitable purpose that sees them working to help those outside Australia then there are standards they have to uphold. It's pretty plain and pretty simple.

This is where the External Conduct Standards come into play. Reasonable steps to comply with the standards to ensure the money for example, that they send overseas has been used appropriately for a charitable purpose.

Now, we mentioned reasonable steps again. What are maybe some of the common things that can be thought about here, Matt?

Matt Crichton

Again, it depends on the situation but some common things that a charity can do is keeping records, of course, which all charities should be doing anyway, a particular focus on the records of the overseas activities in the broadest sense involved, checking recipients of funds so check in on the projects you're funding.

Check in on the organisations running the projects you're funding or you're contributing money towards. Ensure that your charity, in this case likely your religious organisation, has reports on activities and the work going on overseas.

Importantly, are any vulnerable people involved? This is an important consideration. And it's one that may be overlooked sometimes particularly if your involvement is limited to sending some money overseas.

It's likely that these sorts of considerations aren't going to pop up when discussing who to send money to, which organisations send money to. But it's worth keeping this in mind. So consider the work of the organisation overseas and whether or not at any stage, there are vulnerable people involved because you have some obligations towards them.

We'll have a look at the next one. Another common question we get here, I'll just read it as you can, too. We send only a very small amount of money overseas to further our work. Do we really need to comply with the External Conduct Standards?

Once again, as you probably have guessed, the answer is yes. We'll add some clarification to that short answer.

Chris Riches

Generally, a charity is considered to be operating overseas even if its activities are only a minor part of its overall work or if it involves only sending a small amount of money overseas or the activities are being undertaken by another organisation on the charity's behalf. Of course, if that's the case, if you are operating overseas, the External Conduct Standards apply.

Next one. We work with another organisation to deliver our services and efforts overseas. What do we need to ensure?

Now, there's a few things here. This isn't a yes or no one, this one.

The registered charity, the registered Australian charity, in this case your charity, it must comply with the External Conduct Standards for its own activities overseas as well as those of any overseas partner organisation.

Now, we've used the term third party here a couple of times. This is what we mean when we talk about a third party. The charities have to be aware of all the things that are happening through the, I guess we call it the supply line of their work, the scope of its work, the work in its entirety. In doing so, they need to ensure everything is as it should be.

Your charity shouldn't be looking to work with just anyone. Now, that's probably common sense. But again, we emphasise that shouldn't be looking to work with an organisation or individual, that isn't going to uphold certain standards either. That's why charities operating overseas need to have that wider view, that supply line view and need to take into account those third parties that they work with.

Matt Crichton

We don't want to make it sound too onerous but it would be part of a responsible charity's due diligence step, I suppose, in getting involved with some work overseas. No matter what extent that work is, whether it's sending people overseas or just money as we mentioned.

So being aware of all the flow-on effects of being involved in charitable work overseas is important in considering the, as Chris described it, the supply line of your involvement overseas.

But there is one thing though, if the third parties, as we've called them that your charity works with is itself an ACNC-registered charity then, of course, it has its own obligations to comply with the External Conduct Standards.

So it does differ slightly there depending on the partner organisation you've got. So in that way, your charity can ensure it's doing the right thing and its partners are doing the right thing, if it is working with another registered charity which has to comply with the External Conduct Standards itself.

Chris Riches

Next question that we've received and it's one that has been quite common. We are a small charity with a small amount of overseas activities. We are worried about how much work we'll have to do to comply with the External Conduct Standards. Now, this is again we've mentioned through the webinar here, reasonable steps and that sort of stuff.

What's important to remember here is that complying with the External Conduct Standards is a proportionate thing. Every charity is different and we wouldn't expect a small charity to go through all the same processes and steps that a large charity doing a lot of work overseas has to do. The important things to remember here are having a responsible and reasonable approach and a proportionate approach, depending on the size of your charity and the scope of its overseas activities.

Also the word reasonable was used here. Again, it's not a prescription from us as to what is reasonable. The need here is for the charity to consider what is reasonable in the context of its own work, its activity, the scope of what it does.

Really scrutinise, really have a good think. Don't just glide along. Really have a bit of an examination of what you do as a charity and the work that you do overseas.

Charities really should be realising that they need to take some time to think about this and their own circumstances so that their response and so that their approach is reasonable and responsible and proportionate.

Matt Crichton

Of course, at the moment, charities are facing a lot of challenges as we're all well aware. That's both work here in Australia as well as overseas. These things can all have a significant effect on - of course, we're talking about the pandemic, first and foremost. It can have a significant effect on charities work overseas.

So it's important here to recognise that the External Conduct Standards aren't just standards with which you must comply in a regulatory sense. They can be used as practical guidelines and in some cases starting points that can help your charity respond to the types of challenges or at least feel more assured that it's doing as much as it can to address the challenges it faces.

Chris Riches

The first challenge that many of us are facing at the moment obviously comes through the pandemic through COVID. It's posing a major challenge for charities everywhere, including charities that operate overseas and it's a challenge that wasn't foreseen at the start of this year.

Look, the past couple of ACNC webinars were focused on charities and the effects of COVID. They're very good and handy general resources aimed at helping charities. We would recommend going to our webinars page on the ACNC website, Have a look.

The March webinar and the July webinar have covered issues in relation to charities and COVID as well as managing money in the wake of COVID with charity, looking at things like charity, finances, forecasting and budgeting and those sorts of things.

Go and have a look at those resources. They're very handy. We also have a dedicated page still up on our website that gathers together a lot of general information for charities. It continues to be regularly updated as well.

The charities operating overseas would most definitely already be looking at the impacts of the pandemic on their work. But with the ECS in mind, the expectation would be that your charity is looking after its people and its resources.

Matt Crichton

So the pandemic has probably thrown this issue up in a way that not many people expected once the External Conduct Standards became a thing. But of course, External Conduct Standard 4 is one that deals with people most specifically and especially vulnerable people.

Now, vulnerable people again is an interesting phrase here. Normally, we speak of vulnerable people as the people your charity is established to try and support and offer services to, and most certainly, that does remain the case.

But of course, the people involved in this may also be part of your charity, their volunteers, the staff and they may be particularly vulnerable given the current circumstances.

So we've got a few points here you can look at and consider. Obviously, policies are needed, personnel policies, policies covering safety, that type of thing. Clearly, charities will already have these policies in place.

Now might be a good time to review them, update them maybe and revisit some of the statements in the policies. Again, there are some good ideas and prompts in the External Conduct Standard resources and in particular, the self-evaluation tool that Chris mentioned earlier. So it's worth going to have a look at those to give you and your charity an idea of what may be needed now.

Chris Riches

For the other actions, again is there a discussion that needs to be had in amongst your charity about whether there's projects or operations that need to be suspended or postponed in the current environment so that people are safe? Do your people need to be withdrawn from certain areas, pulled out of certain areas? If that's the case, how might this impact on those vulnerable people that you set out to help?

These are questions and these are things that you're going to have to think about. From a very practical standpoint, we say protection here. We talk actual literal protection equipment for your staff or for those that you work with, PPE equipment, for example, or even measures or protection in buildings or premises that they work in.

Matt Crichton

Some resource for this, all three other External Conduct Standards do come into play but a couple of points to think about. Think about the way your charity's resources, that is the funds, equipment, other items as well, are tracked and used. General good practice in governance dictates these things are used properly and responsibly, of course, but there may be changes in situations right now.

One of the challenges is that some of the changes may be so rapid that it can be hard to keep up. So it's important to place some focus on that.

Review the charity's work and what it's doing as well as the policies that cover that work. Is the charity and its people adhering to the policies that are set in place? Do you need to update them? Do you need to alter them? Are there aspects of them that are somewhat irrelevant now given the current circumstances and need to be fixed up to suit the situation that the charities currently finds itself in?

Chris Riches

The last one on that list there, record keeping. As we've said before, record keeping is something that your charity should be doing just as a matter of cause and good governance, good operation obviously. But if you're making important financial decisions or operating decisions, your record keeping needs to be on point, needs to be tracking everything properly. Again, basic tenet of good governance, something that charities must comply with through the governance standards as well.

Ensure the way you keep records and record decisions, is fitting to the current circumstances and actually allows you to keep track of things in the current situation. The other thing about record keeping too, ensure that records are kept in a way where they're easily accessible for those who need them. They're easily understandable and easily read and used where required.

One other aspect of what COVID's done is it's placed a pretty big obstacle in terms of the limitations on travel. These sorts of restrictions may predicate any actions your charity takes on top of those that are already set down through the External Conduct Standards.

It's important your charity is acting lawfully. Obviously, if you can't travel somewhere, you can't travel somewhere. You've got to act lawfully and you have to adhere to those restrictions including those that might be on travel.

Matt Crichton

If travel restrictions are having an effect, there might be other steps that it might have in place to help with decision-making processes or a charity's approach to its work, its services and the behaviour of its staff.

So for example, what will your charity do if its activities are in an area where no travel is allowed and people simply can't come and go easily? What do your policies say in this situation? How do you communicate this with your charity's people, whether that'd be its staff volunteers, its beneficiaries or even broadly to its supporters?

Can you continue the charity's work as usual or will you have to make some decisions on other ways to try and keep services going or possibly even suspend them?

Of course beyond COVID, the External Conduct Standards and their application overseas means that unrest in many parts of the world will affect charities' operations.

The practical implications, of course, will depend on the area in which a charity works. Some are obviously more dangerous than others and will have a greater effect on how your charity will approach their work.

Chris Riches

To that end, I guess again we're looking at things like preparation and procedures and clear communication. That's going to help your charity to obviously addressing the issues but also to comply with the External Conduct Standards. Some of the questions or talking points here is will the unrest make it more difficult for you to get the job done? Will there be increased costs? Will there be increased danger to your people or to the people that you work with? Is there an increased chance of corruption? People overseas perhaps are asking for, we'll call them extra considerations, to allow you to continue to do your work. Will the unrest simply make it too hard for your charity to do its work at all?

Again, there's no easy answers here. There's no blanket answers here. Each charity operating outside Australia will need to look at its own situation, the work it does, where it's operating, these factors, to ascertain where it's got to go and the next steps that it has to take.

The External Conduct Standards however, they can offer some prompts though. Safeguard your resources. Keep good records. Ensure your policies are adequate enough for your organisation to comply with the External Conduct Standards as well as the governance standards.

Matt Crichton

Again that self-evaluation tool, that External Conduct Standards self-evaluation tool that Chris mentioned a couple of times can come into play here as a practical reference. There are some practical ways to ensure your charity is meeting the standards and some of them are quite simple actually. We would hope they're sorts of things charities are doing anyway but we'll mention some of them here.

So just keep abreast of events in the areas in which your charity is operating or has operations including sending funds. Make sure your charity has procedures for helping staff in trouble whether that'd be evacuations, flights back home or flights to other safe areas if needs be.

Policies that dictate how it will pause operations or suspend operations if needed. Make sure the charity has adequate training and preparation. This is probably more relevant for organisations that send people overseas, I suppose. Make sure the people going are adequately trained and prepared for the work they're doing in the country that they're going to be doing it.

Increase the communication with people in an area. Ensure communication is clear, comprehensive, and that the people the charity works with including its own supporters, its donors as well as staff and volunteers have regular and two-way communication channels open with your charity.

Of course, keep the vulnerable people standard in mind. Look after the vulnerable people whether they be your own staff or the beneficiaries at all times.

Chris Riches

Also with communication too, look at the ways that you communicate normally. Perhaps there needs to be different ways used as well. So consider the best ways possible to get messages and get important messages to the people you need to in the quickest possible time as well.

One issue that charities the world over are experiencing and facing is a reduction in donations and funding in the current climate. I guess the question from a charity working overseas' perspective is, is the charity's work going to be affected by a reduction in donations or fundraising? Again, we've talked about this issue in a couple of our previous webinars. I would recommend going and having a look particularly at the webinar that we did in July that looked a lot at the work that perhaps needs to be done in a forecasting way and with financials when it comes to drop-in donations or fundraising opportunities. That's well worth a look.

But a couple of key points here. The ACNC Governance Standards and also the External Conduct Standards obviously, they emphasise how important it is and they set in place, as a requirement for compliance or as a requirement to remain a registered charity, aspects of proper financial management, financial reporting and record keeping.

So look, that's pretty clear. Of course, these types of actions are reflective also of overall good governance practices that any charity should adhere to just as a normal way of operating.

Matt Crichton

In these specific circumstances, there are other actions to consider. So maybe your charity needs to consider small planning about financial forecasting in the coming months given what we've seen and the challenges that charities are facing in the first half of this year.

What sort of communications are you going to need to have with third parties, with people overseas or partners if there are going to be changes to the programs that you're involved with? How are you going to communicate your charity's strategic plans to everyone that needs to know?

We'll just move on to some top tips, we've called them, before we get to a few questions. We've got a few here, the sort of large takeaways that may be useful if much of this has washed over you so far and there's been a lot of information so it's certainly understandable if it has.

But number one here, the External Conduct Standards apply to registered charities that operate outside Australia, even if those operations are small. Of course, we're speaking about operations in that really broad sense which involves sending money overseas and some of those less direct activities.

Chris Riches

Second tip that we've got is, I guess linked to that is the importance of charities taking again the proportionate approach to complying with the External Conduct Standards.

The ACNC expects that charities take reasonable steps. There's that phrase again, reasonable steps, to comply with the standards. Again very important, reasonable steps will vary for each individual charity. This is not a one size fits all. As we know, charities are all different. They are unique. They operate and do different things.

We don't want a cookie cutter approach. It's an approach that needs to take into account the circumstances that are unique to each individual charity. The third point?

Matt Crichton

You go.

Chris Riches

I'm going to go ahead. Good, I'm just getting a roll on here!

The current circumstances that are facing charities that are operating overseas, we'll probably see many charities facing new challenges or at least some challenges that are very different to what they may have expected even just six months ago.

It's important to remember that the External Conduct Standards aren't just a set of rules to abide by, but they are also very handy guidelines and very handy reference points that help charities respond meaningfully to challenges, especially challenges that they may be facing now.

Matt Crichton

Just the last one, that self-evaluation tool is a really handy resource to keep - one to do and then to keep on record and review it and revisit it regularly to make sure your organisation is doing what it's supposed to do to meet the External Conduct Standards.

Chris Riches

We've gotten near the end of our formal presentation which is good and we're getting along towards the end of the hour here. Just a reminder that we are recording the webinar and the recording as well as the slides links an email out to you. They're all going to be coming to you in the next day or so. We will get in touch via email to ensure that you know that this recording has been uploaded, that slides in the presentation are available, and that there are some links that you can go and refer to. So that's important.

Feel free to keep an eye out for that email and click on those links and follow them through.

We've got a couple of questions that have come in during proceedings here. The first one is actually a pretty good one. It's one that again has been asked about relatively commonly. How the ACNC's External Conduct Standards, how they are linked to or related to the ACFID, the Australian Council for International Development or its Code of Conduct? Matt, did you want to explain the link here?

Matt Crichton

Put simply, we've got some more detailed information on the website about this. But if a charity complies with the ACFID Code of Conduct, ACFID that is, it's likely to be meeting the ACNC's External Conduct Standards by virtue of what that Code of Conduct requires of a charity. Because members of ACFID are required to meet these standards, it's likely that these organisations will also be meeting the External Conduct Standards.

But of course, the two things don't exactly map to each other perfectly. So which means that a charity may still need to do a few extra things to ensure they are complying with the External Conduct Standards. But of course, it's been a bit of a theme through today's webinar. That will depend on the charity's own work overseas. The short answer is that it's likely that if a charity is complying with the Code of Conduct from ACFID then it's likely that they're going to be meeting the External Conduct Standards.

But we'll include a link in the follow-up email that has some more detailed information about this. So if you want to look into it more deeply then that will be the place to go.

Chris Riches

There's actually a page on our website that maps the Code of Conduct and the External Conduct Standards and has a bit of a comparison, a bit of a discussion there. So again, that's one worth bookmarking and one worth keeping in mind.

We've gotten and received, we actually have received some questions throughout today's webinar. We also got some queries prior to today's webinar starting and we've touched on it. We're going to emphasise it again because we reckon it's pretty important.

These questions have asked about specific measures, specific things that charities, their charity can do in specific circumstances or policies they should have in place to ensure that they're doing the right thing when it comes to the External Conduct Standards.

Again, we'll emphasise this again. There isn't a one size fits all. You've heard the words reasonable and proportionate being used throughout things today. Charities are different. Each one is unique.

What is reasonable for one charity might not be reasonable for another. Measures put in place by a larger charity are again unlikely to be suitable for smaller charities. Measures put in place by a charity that has a lot of operations overseas are not likely to be right for ones that maybe just send a little bit of money overseas or have a small amount of operations.

What we want to emphasise is when we say reasonable and proportionate, it isn't a prescription from us as to what's reasonable or proportionate. We want to ensure that charities have the opportunity to set in place measures that do the job for them and are right for them.

The need here, in this context, is for a charity to consider what is reasonable in its own context, in the scope of its activities, what it does, where it works, who it's working with, whether it's money, whether it's resources, whether it's activities.

This is where the ECS toolkit, the checklist, comes into play. It's a great reference point. It's a great guide. It literally provides all manner of ideas and points and checklists and questions to prompt you and to help you with suggested measures your charity can take and some steps that your charity can take.

As you work through the toolkit, there'll be times where you'll be able to very quickly figure out what works for your charity, what's reasonable and what might not be reasonable. So that's a bit of a prompt towards self-reflection, charities again needing to consider their own circumstances and their own capabilities as well.

So that's very important and again, we point you in the direction of the self-evaluation as well. It's invaluable. So go, it's a handout here so you can access it. You can also go to the website and download it from there as well. Have we got any more, Matt?

Matt Crichton

I suppose there's one more that I think is worth touching on before we wrap up. Someone is asking about their charity being provided with an opportunity to do something more with their overseas work at very short notice.

They're wondering how they ensure this type of situation is covered as part of the External Conduct Standards.

I can see how this could crop up. You're doing some good work overseas and of course, through networks, which is the way many of these things may come about and some more work or a new project suddenly comes on the radar.

But in some ways, this isn't really much of a question about the External Conduct Standards as much as it is about your own charity's existing policies and procedures.

Your charity should already have in place the policies and procedures that would ensure this type of situation, that it can still meet the External Conduct Standards within this type of situation that these policies would cover. Things like working with third parties, the financial aspects, management of staff and volunteers, even decision-making processes, that sort of thing.

So, if a charity has these sorts of policies and procedures in place and for an established charity that's been doing work overseas, you would assume that that is the case.

For newer charities just getting into this sort of work, it can take a little bit more time to think this through at the outset. But it means that you will be able to take on new projects, new activities and work at short notice because within your governance structure, there's a really clear solid and working policies and procedures that will support your charity in doing that.

Chris Riches

Now, that's it probably, just looking at this watch here and being accompanied by a barking dog. I do apologise. We're all working remotely as you can quite obviously guess. That might be just about it for today.

What we'll do, obviously on the screen at the moment, you can see the ways that you can stay in touch with us. Our e-newsletter Charitable Purpose which comes out and updates people about what's going on around the ACNC, but also obviously around charities as well.

Our webinars, our great podcasts where you will get to hear more of Matt's dulcet tones chatting about all manner of things and our contact, therefore our advice services email.

Thank you very much to everyone who's tuned in today. Thank you to Jess and to Robin and to Matt times two for presenting, for answering some questions, for helping out.

We hope you enjoyed everything today. We hope that it was informative, helpful.

Again, keep an eye on our website and our webinars as part of our website. We've got a number of webinars scheduled between now and the end of the year. So go have a look. See if you're interested in them. Sign up, register, by all means.

Thank you again for joining us. We look forward to catching up again in the near future. Have a great day and most importantly, stay safe. See you later.