Public governance
Everything a donor, foundation, or regulator would want to know about how Life Without Debt Ltd is structured, registered, staffed, and held accountable. Updated as each formal instrument lands.
Registration status
Life Without Debt Ltd is a proposed Australian Public Benevolent Institution. The following instruments are in process. Each will be published to this page as it is issued.
Two-entity structure
Life Without Debt Ltd is the charity. Credit Mediation Services Pty Ltd is the licensed practitioner entity. They are legally separate. They operate under a formal arm's-length service agreement. This structure is what makes the 87c-on-the-dollar donation efficiency possible.
Life Without Debt Ltd
- Type: Company Limited by Guarantee
- Status: ACNC-registered charity (pending)
- Endorsements sought: DGR Item 1, PBI
- Purpose: receives donations, provides free services
- Regulators: ASIC (corporate), ACNC (charitable)
- Employs: most staff
Credit Mediation Services Pty Ltd
- Type: Existing Pty Ltd (commercial)
- Holds: Australian Credit Licence No. 387398
- Role: provides licensed practitioner services to cases referred by the charity
- Principal: Laurence Hugo (Founding CEO of the charity; disclosable related party)
- Arrangement: formal service agreement with the charity
- From Year 4: absorbs infrastructure costs (ACL, PI, tech stack) to preserve donation efficiency
Why this structure? Charity law and consumer-credit law are two different regulatory regimes. Keeping the ACL — a commercial licence with commercial obligations, professional indemnity, and complex compliance overhead — inside a commercial entity, while keeping the charity focused on charitable purpose, is a well-established Australian model. Similar two-entity structures are used by legal-aid services, disability advocacy organisations, and financial-counselling networks.
Founding team
Full Board formation, including two independent non-executive directors, is underway. The founding directors are:
Independent directors
The Board Charter provides for two independent non-executive directors in addition to the founding executive directors, giving a minimum board size of five (three executive plus two independent) once formation is complete. A Director Recruitment Brief has been prepared and is being progressed. Independent director appointments will be announced on this page as they are confirmed.
Related-party disclosures
Every foundation, corporate partner, and regulator that asks about the founder's related interests will see the same answer, in the same place, disclosed plainly. This section is the single source of truth.
- Laurence Hugo is the Founding CEO of Life Without Debt Ltd and the sole director of Credit Mediation Services Pty Ltd, which holds Australian Credit Licence No. 387398 and provides the licensed practitioner services to cases referred by the charity. The service agreement between the two entities is arm's-length and Board-approved.
- Lisa Hugo is the Co-founder of Life Without Debt Ltd and Laurence Hugo's spouse. Her role is Head of Philanthropy in the charity. This relationship is disclosed to the ACNC as part of the charity registration application.
- CoSai CFO Services provides fractional CFO services to Life Without Debt Ltd under a Board-approved services agreement. Carla Oliver is the principal and is independent of the founding-family related-party interests.
- Cross-entity referral arrangement. All referrals from the charity to Credit Mediation Services Pty Ltd are documented in the case file. The charity does not pay Credit Mediation Services for referred casework; CMS carries its own operating costs and absorbs infrastructure costs from Year 4 onwards. The service agreement is available on request.
AI-assisted content governance (HAS §8.5)
Life Without Debt uses AI systems to draft marketing content, grant narratives, and administrative documents. We are deliberately transparent about this because the same discipline that governs our practitioner casework also governs our content: agents draft, humans decide.
The Human Agency Scale (HAS) — how it applies here
The Human Agency Scale is a governance framework that rates AI-assisted work on how much authority the AI system holds versus how much authority the human retains. Life Without Debt operates on a five-band scale:
| Band | Meaning | Applied at LWD to… |
|---|---|---|
| HA1 | AI drafts freely | Initial drafts of marketing copy, ad variants, brief responses |
| HA2 | AI drafts with structural constraints | Structured content (email nurture kits, campaign briefs) |
| HA3 | AI drafts with policy constraints | Regulated content (all donor-facing copy) |
| HA4 | Human reviews and edits before publication | All content going to donors, foundations, corporates, government |
| HA5 | Human authors from scratch; AI never touches | Board minutes, ACNC filings, ATO applications, legal documents, client-case decisions |
The rule (HAS §8.5): nothing produced by an AI agent reaches an external channel, donor, or regulator without a named human approver logged against it. Every marketing asset in our production pipeline carries six compliance flags (RG 96 hedged language, labelled composites, no PII, no named case without consent, Australian English, brand consistency) that must all be affirmatively ticked by a named human reviewer before the asset can be marked approved. This is enforced in software, not just policy.
Client casework is never AI-assisted at HA1–HA3. Advocacy decisions, negotiation strategy, and creditor engagement are HA5: performed exclusively by our licensed practitioner. AI is not present in the negotiation room.
Compliance instruments & policies
The formal instruments that govern how Life Without Debt operates. Available on request; being progressively published as the registration cycle completes.
- Constitution — Company Limited by Guarantee, dissolution clause to another charity, charitable purpose aligned with Charities Act 2013 s12. Drafted.
- Board Charter — Board composition, meeting cadence, delegation, conflicts protocol. Drafted.
- Conflicts & Related-Party Register — live document, updated at each Board meeting.
- Privacy Policy — aligned to Australian Privacy Principles under the Privacy Act 1988 (Cth). Australian-hosted data infrastructure.
- Client Authority Document — the limited scope-of-representation instrument signed by every client. Reviewed by legal.
- Compliance Plan — ACNC Governance Standards 1–5, ASIC RG 96, ABA Banking Code Part 4, AFCA rules, ATO PS LA 2011/17.
- Complaints Handling Policy — internal dispute resolution, escalation to AFCA for licence-related complaints.
- Compliance Calendar — every recurring lodgement, review, and audit deadline captured. Live document.
- Whistleblower Policy — per ASIC/ACNC requirements once staff numbers reach the threshold.
Financial reporting
Once registered, Life Without Debt Ltd will publish its Annual Information Statement and financial statements on the ACNC Charity Register. The first Annual Impact Report — the aggregated case-outcome document described on our Impact page — will publish in the year following our first full operating cycle.
Financial reporting complies with the ACNC financial reporting requirements for medium/large charities (once we cross those revenue thresholds), the Australian Accounting Standards, and independent external audit requirements. Board-Appointed CFO Advisor Carla Oliver (CPA) is responsible for the financial-reporting stack.
Contact for governance enquiries
For governance enquiries, related-party questions, or requests for any of the instruments named on this page, contact:
Carla Oliver — Board-Appointed CFO Advisor — governance@cosailifewithoutdebt.org
This page is a living document. Every material instrument — the ACNC certificate, the DGR endorsement letter, the signed Constitution, the Conflicts Register, the first Annual Information Statement — will be published or linked from this page as it is issued.