Bruce David Hales has never answered questions in a parliament. He is scheduled to do so at 1.00pm on Friday. Three weeks before that date he sent the committee a letter instead — six pages, twenty-seven questions, answered in advance and in writing, with a closing line inviting the committee to accept it in place of his attendance. The letter also does something no one expected: it corrects, on the record, the sworn evidence his own spokesman gave in August.
What the document is
Submission 366 is addressed to Mr Samuel Thompson, Inquiry Secretary, Joint Standing Committee on Electoral Matters, and dated 5 October 2026. It responds to an invitation the committee issued to Mr Hales on 17 September 2026. It is signed “Bruce D. Hales, Eastwood, NSW”.
It has two parts. Part A corrects the evidence of Lloyd Grimshaw, who appeared for the church on 21 August. Part B answers twenty-seven questions — which, as set out below, Mr Hales wrote himself.
Before either, Mr Hales sets out his position:
“My role as regarded by the Plymouth Brethren Christian Church is that of the most senior elder of the Plymouth Brethren Christian Church globally. My role includes giving spiritual guidance to members, so they can live by the principles of the Holy Bible and caring for them as requested by them in their everyday lives. As with leaders of other faiths, it is not my role to direct what members do politically.”
And the framing he wants the committee to adopt:
“I would ask the Committee to consider why a faith leader should be asked to account for the political choices or alleged actions of private individuals who share his faith. The same would not be expected of leaders of other faiths, and I would ask only to be treated in the same way.”
That is the argument the whole letter rests on, and it is worth saying plainly what is wrong with it. No other faith leader in Australia is the named beneficiary of a membership test written into trust deeds approved by a charity regulator. No other faith leader presides over a structure in which a central panel sets the profit-donation percentage for members' businesses. The church is not being asked to account for itself because of what it believes. It is being asked because of what it owns, what it coordinates, and what it is worth.
Part A: he corrects his own spokesman
This is the part that matters most, and it has barely been noticed.
On 21 August, Senator Mulholland put to Mr Grimshaw a report that Mr Hales had recorded an audio message to members two weeks into the campaign and distributed it on the Global Media Stream, a Brethren-only app. The senator read out the phrases: that “booths are manned”, that “volunteers are fired up each day to dominate the play”, and that “we must keep pressing the flesh, shaking hands and talking to voters”.
Mr Grimshaw did not say the words had not been spoken. From the official transcript, he said:
“Those short few words were spoken in what we call a ‘Bible meeting’ or Bible reading… Someone has selectively taken five words from an hour-long discussion and are trying to make out that this is a political message. It's not the context it was given in, and the meaning of those words has been misinterpreted as well as the purpose in which they were given.”
Six weeks later, Mr Hales writes:
“I believe Mr Grimshaw thought he was being asked about my remark that ‘Australia needs to be happy again, smiling again’, which I made in a Bible reading on 20 April 2025. The words I am alleged to have stated (“booths are manned”, “volunteers are fired up each day to dominate the play” and “pressing the flesh, shaking hands and talking to voters”), which were referred to by Senator Mulholland, were not my words. I did not make these statements and have not spoken these words in a Bible meeting or at any other time.”
Read those two passages together. The committee is now being asked to accept that Mr Grimshaw — who had just heard the three phrases read aloud, and who responded by explaining the setting in which those words were spoken, defending their context, and complaining that five of them had been taken selectively from an hour — was in fact answering about an entirely different sentence that nobody had quoted to him.
One of two things follows. Either the church's nominated spokesman gave a detailed contextual defence of words his leader says were never uttered, under oath, without noticing — or the correction is wrong. The committee is entitled to resolve that, and it cannot resolve it from a letter.
Note also what the correction does not dispute. It does not dispute that Bruce Hales recorded material during the campaign. It does not dispute that his recordings are distributed to members on a members-only application. At question 10 he confirms the practice himself.
Part B: twenty-seven questions he wrote himself
Before the answers, the most important thing about them.
The committee did not ask these questions. Mr Hales did. He says so himself, twice. In his opening he writes that he provides “these comprehensive responses to the questions I understand the Committee is most interested in”. At the head of Part B he writes that they are “based on the questions raised by the Committee with Mr Grimshaw at the hearing on 21 August 2026, and the matters raised in various Submissions”.
So the twenty-seven items below are not a questionnaire he was sent. They are his own account of what he expects to be asked, drafted by him or on his behalf, worded by him, selected by him, and answered by him. He then closes by asking to be excused from appearing on the basis that they have been dealt with.
That is worth stating plainly because it changes what the document is. A witness who sets his own paper decides what is on it. Every question that does not appear — about the Global Advisory Panel, about the company the church owns, about the Vision Foundation, about what Strive is for — was left off by the person answering. And it explains an oddity the reader will meet at question 18, where the answer is word for word the answer to question 17: he wrote both.
With that in mind, here is every question as he framed it and every answer as he gave it, in his own words and his own order, with what the documentary record shows against each. Where we hold nothing relevant, we say so.
1. What is your role? Are you the senior leader or “Man of God”?
“I am recognised as the Church's most senior elder globally. This recognition does not equate to an official office: not one single member has appointed me, nor voted for me other than recognising me informally and collectively as the most senior elder of the Church. No one votes for leaders among us, and there is no position to hold or resign. I do not use the title ‘Man of God’.”
What the record shows. There is no election. There is a legal instrument. Under the Deed of Variation annexed to the UK Charity Commission's registration decision of 3 January 2014 — the deed on which the Preston Down Trust was registered, and on which the model for the English congregations rests — a member of the congregation must be “in fellowship with Mr B D Hales (so long as he lives)”. Only such a person may be a trustee. A trustee who ceases to meet the test “shall thereupon cease to be a Trustee”. Where there is doubt, the Minister of the Lord in the Recovery “may by writing in the stipulated form declare whether any person is or was at the particular time in fellowship”, and that writing is “conclusive evidence”. He may remove existing trustees as he considers appropriate. Appeal against removal lies to him, and his decision is “final and conclusive”. The deed cannot be amended without his written sanction.
Mr Hales is right that nobody voted. He is named in the document anyway. A role that cannot be resigned and that expires only with the life of the holder is unusual, but it is not the absence of a position — it is a stronger form of one, and a charity regulator approved it.
2. What authority or influence do you hold over the fellowship and its 287 congregations?
“My authority or influence is based on my moral and spiritual qualifications. The Plymouth Brethren Christian Church has no hierarchical structure, no clergy and no appointed ministers. It is comprised of 82 autonomous congregations across Australia and 287 worldwide, each of which takes responsibility for its own functions… I do not have authority over members' political choices, their businesses, or how they take part in civic life.”
What the record shows. On congregations being autonomous: a trust deed for the Papakura Gospel Hall Trust in New Zealand, dated 21 February 2006, carries the same fellowship machinery as the English deed eight years earlier — and goes further. No hall may be sold without “the prior sanction of the Minister of the Lord in Recovery”. Its cover page reads “© 2005 This Deed is Copyright to The New Zealand Church & Gospel Halls Assistance Fund.” These deeds were not written locally by autonomous congregations. They were drafted centrally, copyrighted, and exported.
On businesses: the church's own internal diagram, titled “The Community Ecosystem”, places GAP — the Global Advisory Panel — at the centre, and groups the church's entities under five headings. The first is “Improve profits of Community businesses”. The Global Funding Team volunteer handbook, copyright The Grace Trust, describes charities submitting their requirements to the centre, the centre aggregating them into a National Target, dividing that into area targets, allocating five to ten named donors to each delegate, and issuing monthly reports on shortfalls against pledges. It describes the planning step as “similar to Sales Planning”. More than 550 people work on the UK team alone. Businesses receive donation guidance expressed as a percentage of net profit, varying by region.
On the number: in written evidence to the House of Commons in 2012, the church counted itself “across our 200-plus trusts (300 or so halls)” and referred to “16,000 Brethren and over 300 gospel halls across the UK”. Halls are not congregations and the two counts are not directly comparable — but the figure Mr Hales gives for the whole world is smaller than the figure his church gave for Britain alone.
3. Are you leader of the fellowship, or only of the Secretariat Entity?
“The Plymouth Brethren Christian Church includes both the Secretariat Entity and the fellowship, it is one church, one fellowship… I am recognised as the most senior elder of the Church globally. However, I hold no office in it, and I am not a director of the company that performs the Church's administrative work.”
What the record shows. This is the most consequential answer in the letter, and it is a concession.
Mr Grimshaw's evidence in August was given on behalf of Plymouth Brethren Christian Church Limited — the secretariat company — and not the fellowship. The committee chair, Jerome Laxale, said afterwards that this “puts huge limits around the church's denials”.
Mr Hales has now removed the limit. There is one church and one fellowship. And in the next sentence he says he holds no office in it. The committee has therefore been told, by the two most senior voices the church has offered, that the body is single and that nobody within it holds a position capable of answering for it.
4. Were you involved in any planning, coordination or direction of members volunteering in the 2025 Federal Election?
“In respect to the 2025 Federal Election, I had no involvement whatsoever in any planning, coordinating or directing of Plymouth Brethren Christian Church members to volunteer or participate as to which I still have no knowledge. The only knowledge I had of any participation in the 2025 Federal Election was through the media.”
What the record shows. Nothing in our records places Mr Hales in the planning of the campaign, and we do not assert that it does. What the record establishes is capability: in the Global Funding Team the church operates a documented national machine that sets a target centrally, breaks it into areas, assigns named households to named delegates and reports monthly on who has not delivered. Whether that machine was used at the election is precisely what the committee is trying to establish, and it is not something a letter can settle.
On the last sentence, it is worth noting what is being claimed: that thousands of members of his church worked polling booths across the country, that this was reported globally for eighteen months, and that the church's most senior elder learned of it from the newspapers.
5. Did you instruct, or were you consulted about, thousands of people in different cities having the same idea?
“No. I had no knowledge of this, nor did I instruct any of them to do so.”
What the record shows. As above. The church has a demonstrated structure for making thousands of households in different cities act on one plan at one time. That structure exists for fundraising. Its existence does not prove it was turned to the election; its existence does mean that “thousands of people had the same idea independently” is not the only available explanation, and the committee does not have to choose between coincidence and instruction without evidence.
6. Were you aware that hotels were used to house hundreds of members during the campaign?
“No. I had no knowledge of this. I did not instruct any members to do this.”
What the record shows. Nothing in our records bears on the hotel bookings. That material is the reporting of the Sydney Morning Herald and The Age.
7. Did the church, through any entity or senior member, fund, donate to or provide support to any party or third party?
“I understand that the Secretariat Entity incurred no electoral expenditure and made no donation in relation to the 2025 Federal Election. I made no donation, payment or contribution of any amount to anyone… Furthermore, I did not instruct, and nor do I have any knowledge of, anyone inside our community/fellowship making any donations — whether financial or in kind.”
What the record shows. The first half of the answer is checkable against the Secretariat Entity's own filings and the AEC's returns. The second half is not, which is why the way it is phrased matters: a statement that he has no knowledge of any member donating is a statement about his own knowledge, not about whether donations occurred.
Our own investigation records that Voltex, a company owned by members of the church, made a political donation, and that a further donation was made in 2025 in the personal name of its owner, Rod Tunley. Mr Hales audits Voltex. See question 15.
8. Did you set in motion, sponsor or know in advance of any plan for members to volunteer for a political party?
“No. I had no involvement in any members volunteering for any political party and was not aware this occurred until reporting appeared in the newspapers.”
What the record shows. See question 4.
9. Did you commission, approve or pay for any advertising connected with the election?
“No. None of any kind.”
What the record shows. Nothing in our records bears on this.
10. Did you record and broadcast an audio message on the Global Media Stream in or around mid-April 2025?
“On 20 April 2025, I led a Bible reading, as I do every week. In it, I observed the state of the world, and I appealed to the congregation to be more fervent in prayer for good government for the benefit of all Australians — and I said Australia needed to be happy again, smiling again. That was worship and a call to prayer.”
What the record shows. The question asked whether he recorded and broadcast a message. The answer describes what he said. It does not deny the recording, and it does not deny the distribution. Mr Grimshaw's evidence in August confirmed the practice directly: Bible readings “are recorded and then made available to members at a later date to listen to in their own time”.
So on the church's own account: on 20 April 2025, two weeks into a federal election campaign in which thousands of its members were working polling booths, the most senior elder of the church addressed the state of the world and the need for good government, and that address was distributed to the membership on a members-only application. He says it was worship. The committee may still want to hear the recording.
11. What were the exact words, and in what context?
“The exact words were ‘Australia needs to be happy again, smiling again’. The context of the recording referred to in the question, was taken from a bible reading in a service that I was leading on 20 April 2025 in our Sydney church in Ermington. I was making a general observation of world affairs and their impact on this country. It was an appeal to the congregation present to be more fervent in their prayers for good government for the benefit and prosperity of all Australians.”
What the record shows. This is the first time the church has placed the recording, the date and the venue on the record. The audio itself has not been produced.
12. Were any senior members involved in planning, coordinating or directing members volunteering?
“I did not direct, approve or fund the activity of any senior member — or of anyone. Whatever others may have done, they did in their own personal capacity.”
What the record shows. The question asked whether senior members were involved. The answer says he did not direct them. Those are different propositions, and only the second is addressed.
On the relationship between Mr Hales and senior members' businesses: he personally audits three companies owned by members of his church — Westlab, Voltex and Bellriver Homes. Westlab took $686 million in pandemic revenue. Voltex is the subject of question 15. Bellriver Homes is owned by David Sandeman, who is a brother-in-law of Lloyd Grimshaw, the man the church sent to give evidence in August; the two are married to sisters.
13. How do you explain coordinated volunteering across Perth, Melbourne, Sydney, Brisbane and regional centres simultaneously?
“I do not know, because I had no part in it. If community members wanted to participate in election volunteering activities together, that was a decision they made in their personal capacity.”
What the record shows. The honest answer to “how do you explain it” would at least acknowledge that the church possesses, and documents, exactly the apparatus required to produce that pattern. The Global Funding Team handbook describes national targets broken into area targets, delegates allocated named households, and central monthly reporting. Simultaneous coordinated activity across Australian cities is not a mystery in an organisation that runs its fundraising that way.
14. Were any chat groups, WhatsApp groups or communication channels used by senior members, including yourself, to coordinate election activity?
“I had nothing to do with the 2025 Federal Election, and I was not involved in any chat groups or communication channels in relation to the 2025 Federal Election, nor was I aware of them. I do not use any chat groups.”
What the record shows. The final sentence is probably true and almost certainly beside the point. The church does not communicate by chat group. It communicates through the Global Media Stream, a members-only application on which Mr Hales's own Bible readings are distributed — as he describes at question 10 — and through Connect, a members-only directory application operated by UBT.
15. Did you personally make any donations to any party, candidate or affiliated third party?
“No. I also do not know of any members who made donations of any kind to any political party or candidate in the 2025 Federal Election and nor did I instruct any of them to do so.”
What the record shows. This is the answer most directly capable of being tested, and the committee should test it.
Our investigation records a political donation by Voltex, a company owned by members of the church, and a further donation made in 2025 in the personal name of Rod Tunley. Mr Hales is the auditor of Voltex. The committee can ask him whether he knew of either, and it can ask the AEC for the returns.
The wording also repays attention. He does not say no members donated. He says he does not know of any who did — about a church of 16,000 people in Australia whose businesses he is close enough to three of to audit.
16. Are you aware of members funding the individuals named in media reports?
“No. I also do not know any of these individuals.”
What the record shows. Nothing in our records bears on this. The payments are the reporting of the Sydney Morning Herald and The Age, which does not suggest that Bruce Hales was directly involved in organising or paying for the stunts.
17. Did you direct, approve or fund election activity by any member of your own family?
“No. I was not aware of, and nor did I direct, approve or fund any election activity for the 2025 Federal Election. The adult members of my family answer for themselves, as every adult does.”
What the record shows. His son Gareth Hales is called before the same committee at 11.30am on Friday, ninety minutes before him. The Sydney Morning Herald and The Age report that the church was referred to as “the client”, that the operation ran through Santé Global — a company owned by Gareth Hales — that his name appeared on payments, and that Santé Global booked the room at the Ryde-Parramatta golf club on 1 April 2025. The mastheads do not suggest Bruce Hales was directly involved.
“The adult members of my family answer for themselves” is, at least, an answer the committee can take up on Friday morning. It is also a proposition his sons contradict in their own words.
Later today we publish a transcript of Strive 26, the church's annual business event, played to the worldwide membership in every time zone. On it, Charles Hales describes going to see his father in 2017 about his American business:
“He always brought us up on that 1 million revenue per person… he asked me what the revenue was going to be that year and I said, I think we might just hit 100 million. And he said, how many staff have you got? And I said 160. And he said, what happened to the ratio that you agreed?… I walked out of the office and we regrouped. In the next eight weeks, we cut 58 staff to get back to that ratio.”
And Dean Hales, about a business of his own:
“I remember sitting down with Jeremy and then subsequently after with dad and Gareth and I remember dad saying, look, you've got an overhead structure to support a $20 million business, but the last six months you've been averaging a run rate of 10 million… So we had to aggressively cut the overheads and it's ultimately what saved the business.”
Neither passage is about the election, and we do not suggest it is. What they go to is the general proposition. Two of Mr Hales's adult sons, speaking to 56,000 people, describe their father setting the operating ratio one of their companies would run at, holding him to a figure he had “agreed”, and being in the room — with Gareth Hales — when the other was told to cut his overheads. Fifty-eight people lost their jobs within eight weeks of the first conversation.
Whatever the adult members of this family do, they do not appear to do it without reference to their father.
18. Did you know that members allegedly organised neo-Nazi or right-wing hecklers to follow and harass the Prime Minister and other MPs?
“No. I was not aware of, and nor did I direct, approve or fund any election activity for the 2025 Federal Election.”
What the record shows. The answer to question 18 is word for word the answer to question 17. The question asks what he knew about an allegation of organised harassment of the Prime Minister. The answer given is about what he directed, approved or funded.
Remember who wrote the question. He set it, and then pasted in the answer to the one before. On the most serious matter in the document, the letter supplies a sentence written for something else.
19. Did you or any member of the Hales family have contact with Mr Peter Dutton, his office or his adviser Mr Sam Jackson-Hope?
“No. I have never met, spoken with or communicated with Mr Dutton or Mr Jackson-Hope — not during the 2025 Federal Election campaign, not before it, not ever — and no one has ever done so on my behalf or at my request.”
What the record shows. Nothing in our records bears on this. Note that the question asked about the Hales family; the answer is given for himself and for anyone acting on his behalf.
20. What agreements or understandings existed between you and the Liberal Party, any far-right group or any activist?
“None. I made no agreement, formal or informal, with any political party, any group or any person concerning the 2025 Federal Election. There was no deal, no understanding — nothing was asked of me by the Liberal Party, and nothing was given by me.”
What the record shows. Nothing in our records bears on this. It is, however, the answer that speaks to the Prime Minister's question about a quid pro quo — and the answer is given solely for Mr Hales personally, not for the church, its charities, its businesses or its secretariat.
21. Have you ever met, spoken with or exchanged money with Mrs Gina Rinehart or any company associated with her?
“No.”
What the record shows. Nothing in our records bears on this.
22. Do you accept the Liberal Party's own election review describing the church as a “support group”?
“I had no involvement in the 2025 Federal Election… The characterisation in the Liberal Party's election review following the 2025 Federal Election is a matter for the Liberal Party to explain. I can confirm that the Liberal Party never spoke with me in relation to the 2025 Federal Election review.”
What the record shows. The Liberal Party's own post-election review found that its members were too old to volunteer on booths, and that “some campaigns were grateful for the assistance” of the Brethren “support group”. That is a document written by the beneficiaries, not by the church's critics.
23. Ex-members have given evidence about a culture of control and direction. What is your response?
“That is not how we live. A member's life is governed by Scripture and by their own conscience before God… we do seek to support and encourage the members of the Church to lead their lives in accordance with their religious beliefs and the values and teachings of the Church but, ultimately, their choices are their own.”
What the record shows. The deeds described at question 1 make a person's standing as a trustee of their own local hall contingent on a written declaration by one man, with no appeal beyond him. The Global Funding Team handbook circulates a meeting invitation reading: “We ask that ALL Households join the Zoom meeting… It is expected that ALL households would attend.” In 2012 the UK Charity Commission refused the Preston Down Trust on a finding of “elements of detriment and harm”, and registered it two years later only on an amended deed.
Whether that amounts to a culture of control is a judgement. That it is a structure of control is a matter of documents.
24. You have been quoted as saying “everything you do in your daily life is Church business”. What did you mean?
“This is not a quotation of mine, and it is not among any of my writings.”
What the record shows. On the narrow point, Mr Hales is correct. The sentence was put to Mr Grimshaw by Dr Monique Ryan on 21 August as a paraphrase — “Among the writings of Mr Hales is a statement that says that everything you do in your daily life is church business” — and those are not words Mr Hales is recorded as having spoken.
The proposition, however, is his. From his published ministry:
“The house of God would involve our whole lives really, and lives here… you can't take one part of your life, and say, That's something different from what I am in the assembly or at the Lord's Supper.”
Vol. 98:34 — Sydney, Reading, Saturday 10 April 2010
“The principle of God's house is… it doesn't just apply at special times or special situations or special locations, you might say, it's meant to be a complete matter, that we would regard ourselves as in the house of God, so that the whole of our lives would be governed by it.”
Vol. 181:170 — Burgess Hill, Reading, Friday 24 March 2017
Dr Ryan's question was whether a doctrine that the whole of a member's life falls under the house of God can be reconciled with the church's position that what members did at the election was private and nothing to do with it. Mr Hales has denied a form of words. He has not answered the question. It is still a good one, and the ministry it rests on is his own, twice.
It is also worth recording how Mr Grimshaw handled it in August. He did not deny the sentiment. He explained it: that in a member's daily life “they're observed as being part of the Christian faith and they should act accordingly”, and that the apostle Paul's “God's house” is “a very broad term”. He was defending the proposition his leader now says does not exist.
25. If no one can speak for the fellowship, who should answer for what members did?
“Any individual should answer for anything they did in relation to the 2025 Federal Election. I have answered for my actions in this letter.”
What the record shows. Taken with question 3 — one church, one fellowship, and no office in it — this is the architecture of the whole defence. The church is one body. Nobody holds a position in it. Therefore nobody answers for it, and the committee is directed to 16,000 individuals instead.
26. Why can the Church not simply account for its members' election activities?
“The Church does not control its members' private lives. To the extent that anyone participated, it was based on their own convictions and not a Church initiative. There is no register of members' private activities, no command structure, and no officer who could truthfully answer for 16,000 private citizens.”
What the record shows. There is a register.
Connect is an application published on the Google Play Store by UBT Global Software Development, a business of UBT Holdings Limited, described as a “Community Directory Application” and downloaded more than ten thousand times. Its published privacy notice records that it holds, for members, their photograph, name, email address, telephone number, home address, place of worship, location, links to other family members and connections by marriage.
Two passages in that notice are decisive. Personal information submitted to Connect is “checked first by UBT staff… to ensure that personal information aligns with PBCC member records” — which means PBCC member records exist, centrally, and are authoritative. And on deletion, UBT states that it will “continue to hold it on our database… for the purposes of verification and ongoing recordkeeping for the PBCC” — which means a company keeps records on behalf of the church, and keeps them after a member asks for them to be removed.
Mr Grimshaw told the committee in August that “there's no centralised recordkeeping”. Mr Hales now tells the committee there is no register. The church's own commercial arm publishes a privacy notice, in public, on an app store, saying that it maintains one and that it checks submissions against the church's member records.
On “no command structure”: the Global Funding Team handbook allocates five to ten named donor households to each delegate and reports monthly on who has not met their pledge. Whatever that is, it is not the absence of a structure.
27. If volunteers harassed or intimidated anyone, what do you say?
“Every individual should answer for what they did. I do not agree with the harassment or intimidation of anyone.”
What the record shows. That is a clear statement and it should be recorded as one.
The closing argument, and the request
Mr Hales ends on religious freedom:
“We are a religious organisation, not a political organisation. Our members should be able to exercise their right to engage in the political process, including by volunteering in their personal capacity, as with any other member of any other faith in Australia, without the Church being required to account for their actions and beliefs.”
Nobody has disputed the right of members of this church to volunteer. The question in front of the committee is not whether a religion may campaign. It is whether an organisation with £1.27 billion of income across 205 charities in England and Wales alone, a central panel that sets donation percentages for members' businesses, a licensed investment fund taking savings from its own members, a school system subsidised at £14,909 a pupil, and tax advantages worth at least £15 million a year in one country, was acting as a church when thousands of its people appeared at polling booths — and whether, if it was not, the charitable status that underwrites all of it is correctly held.
Then the last paragraph:
“I trust that the above responses address the Committee's queries that they would have of me and, as a result, I assume my attendance is no longer required before the Committee. Should the Committee wish to raise any further matters, please provide these questions in writing and I am willing to provide supplementary written responses.”
Twenty-seven questions he set himself. One answer repeats another verbatim. One corrects sworn evidence given by the church's own spokesman. One denies a quotation while the proposition behind it sits twice in the author's published ministry. On the strength of those, the committee is invited to excuse the witness.
It does not have to. A joint standing committee of the Australian Parliament may require a witness to attend. Mr Hales is listed for 1.00pm on Friday 16 October, Committee Room 2R1. His son Gareth is listed for 11.30am.
Five systems the defence requires not to exist
Both men have now given the committee the same account in different words. There is no hierarchy. There is no central recordkeeping. Congregations are autonomous. The church has no businesses and no vested interests. Nobody holds a position capable of answering for any of it.
That account is not contradicted by an allegation. It is contradicted by infrastructure. The church operates five systems, each of them global, each of them centrally administered, and each of them named and described in the church's own documents rather than in anybody's reporting. They are not secret. Four of the five can be read by anyone with an internet connection.
Taken one at a time they are administrative conveniences. Taken together they are the organisation the committee has been told does not exist.
This section is also published on its own, free to read and outside the paywall, with three further bodies and a note on the addresses: The five systems that run the Plymouth Brethren worldwide.
1. Connect — the membership register
What it is. An application on the Google Play Store, published by UBT Global Software Development, a business of UBT Holdings Limited, and described as a “Community Directory Application”. More than ten thousand downloads. It replaced a printed book. It lists Brethren households worldwide with photographs, names, email addresses, telephone numbers, home addresses, place of worship, location, links to other family members and connections by marriage.
What it establishes. That the church knows, centrally and to household level, who its members are and how they are related, anywhere in the world. Its own privacy notice says submissions are “checked first by UBT staff… to ensure that personal information aligns with PBCC member records” — so a master record exists and a company is the custodian of it. And on deletion, UBT says it will “continue to hold it on our database… for the purposes of verification and ongoing recordkeeping for the PBCC”.
What it contradicts. Mr Grimshaw: “there's no centralised recordkeeping”. Mr Hales: “There is no register of members' private activities, no command structure, and no officer who could truthfully answer for 16,000 private citizens.” A church that cannot identify its own members cannot run a worldwide directory of them that is checked against a central list.
2. The Global Media Stream — one voice to the whole membership
What it is. A members-only application on which recordings are distributed to the membership. Both men described it to the committee. Mr Grimshaw: Bible readings “are recorded and then made available to members at a later date to listen to in their own time.” Mr Hales, at question 10, confirms he led the reading in question and describes what he said in it.
What it establishes. That there is a one-to-many broadcast channel running from the most senior elder to the entire worldwide membership, operated by the church, closed to everyone else. Content goes down it. Nothing comes back up it.
What it contradicts. “No hierarchical structure, no clergy and no appointed ministers.” An organisation of genuinely autonomous congregations with no hierarchy does not need, and would not build, a private global distribution network for one man's words. The existence of the channel is the hierarchy, expressed as software.
It is also the system at the centre of Part A. The committee has been told the words on it were spoken in context, and separately that they were never spoken at all. The recording would settle it.
3. The Global Funding Team — the command structure for money
What it is. A volunteer fundraising organisation with its own handbook, copyright The Grace Trust and marked for team use only. Charities submit their requirements to the centre. The centre aggregates them into a National Target, divides that into area targets, and allocates five to ten named donor households to each delegate. Monthly reports track shortfalls against pledges. The handbook calls the planning step “similar to Sales Planning”. More than 550 people work on the United Kingdom team alone.
What it establishes. A chain of command with a centre, regions, named officers, assigned targets and performance reporting, operating across households in every part of a country at the same time. A meeting invitation circulated through it reads: “We ask that ALL Households join the Zoom meeting… It is expected that ALL households would attend.”
What it contradicts. “No command structure.” “Autonomous congregations.” And, most directly, question 13 — how to explain coordinated activity across Perth, Melbourne, Sydney, Brisbane and regional centres simultaneously. The church has a documented answer to that question. It runs one every year.
4. GAP and UBT — the commercial centre
What it is. The church's own internal diagram, “The Community Ecosystem”, places the Global Advisory Panel at the centre and groups the church's entities around it under five headings. The first heading is “Improve profits of Community businesses”, and UBT sits under it. UBT (EU) Ltd sold £107.8 million of consultancy, accountancy, insurance, IT, telephony and vehicle services in 2024, gave away £22.2 million of profit, and recorded a corporation tax charge of £5,970. A recorded Global Funding Team meeting describes GAP as having “oversight” and providing “overall direction to the ecosystem”, with entities sorted into revenue raisers, consolidators and recipients, each submitting a five-year strategic plan reviewed with GAP annually. Businesses receive donation guidance expressed as a percentage of net profit, varying by region.
What it establishes. A central body that directs the commercial activity of members' businesses, sets what proportion of their profits is given, and reviews their plans annually. That is not a church with members who happen to be in business. It is a group structure.
What it contradicts. Mr Grimshaw, to the committee: “there is no such thing as a Brethren business because the church does not have any businesses, it doesn't have any vested interests.” Mr Hales: “I do not have authority over members' political choices, their businesses, or how they take part in civic life.” The diagram is the church's own, and the first thing on it is improving the profits of Community businesses.
5. Vision — the money system
What it is. A licensed New Zealand managed investment scheme that takes savings from Brethren families from $250 and lends them to Brethren businesses against personal guarantees. Its offer document says it is for “members of the Brethren community”. Its investment policy says it lends “predominantly to Brethren Community businesses”. Investors are paid a rate set each month by the investment manager; everything the fund earns above that rate is paid to Vision Invest Trust, which the scheme's own documents say is “ultimately owned by Vision Foundation Limited” — an Australian registered charity with net assets of A$262 million that made no grants to charities in its last financial year. Until January 2023 the fund was called UBT Invest NZ Funds, and until March 2025 its investment manager and distributor was UBT Marketing Pty Limited — the same company that owns Connect.
What it establishes. A closed financial system spanning at least three countries, in which the church's members supply the capital, the church's members borrow it, and the margin accrues to a charity the church controls. Its published privacy policy records overseas disclosures to the United States, the United Kingdom and New Zealand.
What it contradicts. Autonomy. A church of independent local congregations does not operate a cross-border banking arrangement for its own members, administered from one address in Sydney Olympic Park.
What the five have in common
Every one of them is global. Every one is administered centrally. Every one is documented by the church or by a company the church owns — a privacy notice, a handbook, an internal diagram, a product disclosure statement lodged with a regulator. Not one of them comes from a critic, a former member or a newspaper.
And four of the five run through one company. UBT owns the directory that holds the membership. UBT sells services to the businesses. UBT's own entity managed the fund until last year. The fifth, the Global Funding Team, is copyright to the Grace Trust, which in England and Wales made £226.7 million of grants in five years.
Mr Hales's letter asks the committee to treat him as it would any other faith leader. The test he proposes is a fair one, and it answers itself. No other faith in Australia maintains a verified worldwide register of its members' households, a private broadcast channel from its leader to all of them, a national fundraising organisation that assigns named families to named officers against monthly targets, a central panel that sets what share of members' business profits is donated, and a licensed investment fund that takes its members' savings and lends them to its members' companies.
The committee is not examining a religion. It is examining the only organisation in Australia that has all five.
What the committee can now ask
- Mr Grimshaw told you the words were spoken in a Bible meeting and taken out of context. You say they were never spoken. Which of you is mistaken, and will the church produce the recording of 20 April 2025?
- You say there is no register of members. UBT's published privacy notice says personal information is checked against “PBCC member records” and retained for “ongoing recordkeeping for the PBCC”. What are the PBCC member records, who holds them, and how many people are on them?
- Under the deeds approved by the UK Charity Commission, a person's trusteeship of their local gospel hall depends on your written declaration that they are in fellowship with you, and your decision is final and conclusive. How is that not an office?
- You audit Westlab, Voltex and Bellriver Homes. Voltex made a political donation and a further donation was made in its owner's own name in 2025. Did you know of either, and what does your audit role involve?
- Question 18 asked what you knew about members allegedly organising harassment of the Prime Minister. Your answer repeats your answer to question 17 and addresses what you directed. Can you answer the question that was asked?
- You say the church is one body and that you hold no office in it. Who, in that case, is able to answer to this committee for the church?
- The Global Advisory Panel sits at the centre of the church's own ecosystem diagram, and the first heading on it is “Improve profits of Community businesses”. Who sits on GAP, and who appoints them?
How this was put together
Submission 366 is a public document, published by the Joint Standing Committee on Electoral Matters as part of its inquiry into the 2025 federal election. It is quoted here directly and at length so that readers can judge it for themselves; the ordering of the questions and the wording of the answers are the document's own.
Lloyd Grimshaw's evidence is quoted from the official committee transcript of 21 August 2026, with the qualification he gave: that when he said “the church” he was referring to the secretariat entity that is the charity in Australia, and that he was nonetheless “representing the Plymouth Brethren Christian Church and representing the fellowship”. Dr Monique Ryan's question is from the same transcript.
The Preston Down Trust deed is quoted from the Charity Commission's published registration decision of 3 January 2014 and the Deed of Variation annexed to it; the Papakura Gospel Hall Trust deed from the New Zealand Charitable Trusts Register. The 2012 refusal and the subsequent findings are from the Commission's published decisions and from the House of Commons Public Administration Select Committee report HC 76 and the written evidence to that inquiry.
“The Community Ecosystem” is the church's own internal diagram. The fundraising description is from the Global Funding Team volunteer handbook, copyright The Grace Trust, quoted briefly. The Connect listing is on the Google Play Store; the quotations are from the Global Privacy Notice for the Connect Services published by UBT. The charity figures are our own, built from Charity Commission register data for 205 Brethren charities in England and Wales for the years 2021 to 2025, with internal transfers netted, together with the filed accounts of OneSchool Global UK, UBT (EU) Ltd and the Grace Trust.
The ministry extracts at question 24 are from the published volumes of Mr Hales's ministry, cited by volume and page with the date and place of the reading. The remarks of Charles Hales and Dean Hales at question 17 are from a transcript of Strive 26, the church's annual business event held in November 2025, which we publish in full separately.
The account of the election operation — the payments, the chat groups, Santé Global's role, Westlab's pandemic revenue and Bruce Hales's position as its auditor — is the reporting of Michael Bachelard and Sherryn Groch in the Sydney Morning Herald and The Age. Those reports state that the masthead does not suggest Bruce Hales was directly involved in organising or paying for the stunts.
Nothing here alleges that Mr Hales, any member of his family, or any company or charity named has acted unlawfully. The church denies involvement in the election. Where this article says the record shows something, it means a document on a public register or a document we hold; where we hold nothing, we have said so.
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