AUGUSTINIAN SISTERS, SERVANTS OF JESUS AND MARY OVERSEAS DONATION POLICY
 Rationale:

The Augustinian Sisters, Servants of Jesus and Mary of Australia support the missionary establishments overseas:  Augustinian Sisters, Servants of Jesus and Mary:  Malta, Brazil, Philippines
 
This policy outlines the external conduct standards that are required and suggested by the ACNC.
 
EXTERNAL CONDUCT STANDARD 1: ACTIVITIES AND CONTROL OF RESOURCES

• The Augustinian Sisters, Servants of Jesus and Mary of Australia take reasonable steps to ensure its activities outside Australia are consistent with its purpose and character as a not-for-profit
• The Augustinian Sisters, Servants of Jesus and Mary of Australia maintain reasonable internal control procedures to ensure that funds, equipment, supplies and other resources are used outside Australia in a way that is consistent with the charity’s not-for-profit purpose and character, and
• The Augustinian Sisters, Servants of Jesus and Mary of Australia take reasonable steps to ensure that funds, equipment, supplies and other resources provided to third parties outside Australia (or within Australia for use outside Australia) are applied:
  • in accordance with the charity’s not-for-profit purpose and character, and
  • with reasonable controls and risk management processes in place.

The Augustinian Sisters, Servants of Jesus and Mary of Australia comply with Australian laws in the following areas while operating overseas:

• money laundering
• financing of terrorism
• sexual offences against children
• slavery and slavery-like conditions
• trafficking in individuals and debt bondage
• people smuggling
• international sanctions
• taxation, and
• bribery.

 
The Augustinian Sisters, Servants of Jesus and Mary of Australia maintain reasonable internal control procedures to ensure compliance with these laws.
The Augustinian Sisters, Servants of Jesus and Mary of Australia can ensure that the charity is managed in a way that ensures:

• it remains solvent
• any risks to its assets are minimised
• the charity and its resources further its purposes
• its operations are consistent with its purpose and character as a not-for-profit.

 
The Augustinian Sisters, Servants of Jesus and Mary of Australia promote legitimacy and transparency and ensure a registered charity and its resources are not misused for non-charitable or illegal purposes overseas.
 
 
EXTERNAL CONDUCT STANDARD 2: ANNUAL REVIEW OF OVERSEAS ACTIVITIES AND RECORD-KEEPING
 
The Augustinian Sisters, Servants of Jesus and Mary of Australia maintain records that include information necessary for the charity to be able to prepare a summary of its activities and related expenditure outside Australia on a country-by-country basis.
The records kept are for each financial year in which a charity:

• operates outside of Australia, or
• gives funds or other resources to third parties for use outside Australia.

 
The Augustinian Sisters, Servants of Jesus and Mary of Australia charity’s records include information necessary for it to prepare a summary of its operations outside Australia if required.
 
The Augustinian Sisters, Servants of Jesus and Mary of Australia meet the External Conduct Standard 2 if it has records that contain the following information:

• the types of activities it conducted outside Australia on a country-by-country basis
• details of how its activities outside Australia enabled it to pursue and achieve its purpose on a country-by-country basis
• details of all expenditure relating to its activities outside Australia on a country-by-country basis
• details of any procedures and processes it used to monitor its overseas operations
• a list of the third parties it worked with outside Australia
• details of any documented claims of inappropriate behaviour by its employees or Responsible Persons outside Australia, and actions it took in response. This might involve documenting information if it breaks Australian or overseas laws, or breaches its own code of conduct.

The Augustinian Sisters, Servants of Jesus and Mary of Australia records are summarised as below:

• Records are complete, accurate and legible
• Records prepared on a timely basis
• Records are kept in English or in a form that can be easily translated to English
• Records are stored safely
• Records kept for at least 7 years.

 
Records including electronic format and are kept as long as specific information contained in the records is easy to find if a request is made.
EXTERNAL CONDUCT STANDARD 3: ANTI-FRAUD AND ANTI-CORRUPTION

• The Augustinian Sisters, Servants of Jesus and Mary of Australia minimise any risk of corruption, fraud, bribery or other financial impropriety by its Responsible Persons, employees, volunteers and third parties outside Australia, and
• The Augustinian Sisters, Servants of Jesus and Mary of Australia identify and document any perceived or actual material conflicts of interest for its employees, volunteers, third parties and Responsible Persons outside Australia.

EXTERNAL CONDUCT STANDARD 4: PROTECTION OF VULNERABLE INDIVIDUALS

• The Augustinian Sisters, Servants of Jesus and Mary of Australia being provided with services or accessing benefits under programs provided by the charity (whether directly or through collaboration with a third party)
• The Augustinian Sisters, Servants of Jesus and Mary of Australia engaged by the charity, or a third party in collaboration with the charity, to provide services or benefits on behalf of the charity or third party.

‘Vulnerable individuals’ are defined as people under the age of 18, or those who may be either unable to take care of themselves – due to their age, an illness, trauma, disability, or some other disadvantage – or unable to protect themselves against harm or exploitation.